APPENDIX A: 

TIER 1 DRAFT ENVIRONMENTAL IMPACT 

STATEMENT
ATLANTA-CHATTANOOGA

HIGH SPEED GROUND TRANSPORTATION PROJECT

TIER 1 DRAFT ENVIRONMENTAL 

IMPACT STATEMENT 

Prepared by:

Federal Railroad Administration (FRA)

Georgia Department of Transportation (GDOT)

Tennessee Department of Transportation (TDOT)

September 2016

Revised June 2017

PTSCO - 0023-00-002

PI: No. T001684

Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-1 September 2016

0.0 EXECUTIVE SUMMARY

0.1 Overview

The Federal Railroad Administration (FRA), in cooperation with the Georgia Department of 

Transportation (GDOT) and the Tennessee Department of Transportation (TDOT), prepared this Tier 

1 Draft Environmental Impact Statement (DEIS) for the proposed Atlanta – Chattanooga High Speed 

Ground Transportation (HSGT) Project (Project).

1

The Project is a proposed, new high-speed 

intercity passenger service connecting Atlanta, Georgia and Chattanooga, Tennessee.

This Tier 1 Draft Environmental Impact Statement (DEIS) is a program-level document. A programlevel Tier 1 Environmental Impact Statement (EIS) is prepared when large geographic areas are 

being addressed for proposed improvements, allowing the project sponsor to review reasonable 

HSGT corridors, general environmental conditions, and potential impacts. This Tier 1 DEIS states 

the purpose and need for the Project; assesses all reasonable corridor alternatives for the proposed 

action, including a No-Build Alternative; provides a broad overview of the potential transportation, 

natural, and human impacts; and presents the outcomes of public and agency coordination that were 

considered in the assessment and decision-making processes. 

FRA, GDOT and TDOT have developed this Tier 1 DEIS in accordance with the National 

Environmental Policy Act of 1969 (NEPA) and its implementing regulations (40 Code of Federal 

Regulations [CFR] Parts 1500-1508); Safe Accountable Flexible Efficient Transportation Equity Act: 

A Legacy for Users (SAFETEA-LU); Moving Ahead for Progress in the 21st Century Act (MAP-21); 

and FRA’s Procedures for Considering Environmental Impacts (64 Federal Register [FR] 28545). 

Following the Tier 1 EIS process, GDOT will advance the selected Preferred Alternative for further 

study. If a Corridor Alternative is selected, GDOT will advance it to the Tier 2 NEPA process wherein 

more detailed environmental analyses will be conducted, potential alignments within the Preferred 

Alternative will be configured, exact station locations will be identified, a storage and maintenance 

facility site will be evaluated, and an HSGT technology will be selected.

The Atlanta – Chattanooga HSGT Project Tier 1 DEIS began with FRA’s publication of the Notice of 

Intent (NOI) (see Appendix A) in the Federal Register on August 22, 2007. The NOI announced the 

intent to prepare a Tier 1 EIS. Following the NOI, a scoping process was undertaken to inform the 

public, interest groups, and involved agencies about the proposed Project, corridor alternatives, and 

issues for public and agency review and input. Comments and recommendations received during the 

scoping meetings by the public, stakeholders and agencies were used to refine the Project’s 

Purpose and Need Statement, corridor alternatives, and the scope of the environmental analysis to 

be included in this Tier 1 DEIS. A summary of the scoping process, the public and agency 

coordination efforts, and the input received is documented in the Scoping Summary Report (GDOT

2008) and Chapter 7.0 of this Tier 1 DEIS. The corridors emerging from the scoping process that 

were carried forward into the screening phase are detailed in Chapter 2.0.

0.1.1 Project Area Description

For the purpose of this Tier 1 DEIS, GDOT defined a broad geographic Project Area for study that is 

contained, wholly or in part, in the following counties: Fulton, Cobb, Cherokee, Floyd, Bartow, 

Murray, Whitfield, Gordon, Chattooga, Catoosa, Clayton, Douglas, Paulding, Polk, and Walker 

counties of Georgia; and Hamilton County of Tennessee. The Project Area is shown in Figure 0-1.

 

1

FRA defines HSGT as a self-guided intercity passenger ground transportation - by steel-wheel railroad or magnetic levitation 

(Maglev) - that is time competitive with air and/or auto for travel markets in the approximate range of 100 to 500 miles. A 'market' is 

a city pair - two metropolitan areas and markets that, by their proximity and configuration, lend themselves to efficient service by 

ground transportation.
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-2 September 2016

0.1.2 Purpose and Need

0.1.2.1 Project Purpose

The purpose of the Project is to enhance intercity mobility and economic growth throughout the 

Project Area between the metropolitan areas and the airports of Atlanta, Georgia, and Chattanooga, 

Tennessee, by providing faster and more reliable ground transportation service to the public as an 

alternative to highway, intercity bus, and air travel in a manner that is safe and cost-effective, while 

avoiding, minimizing, and mitigating impacts on the human and natural environment. This purpose is 

supported by the Long Range Transportation Plans (LRTPs) of the Metropolitan Planning 

Organizations (MPOs) in the Project Area and the GDOT’s and TDOT’s State Implementation Plans.

0.1.2.2 Need for the Project

Commuters traveling in the Project Area primarily rely on automobiles for intercity travel since there 

is very limited intercity bus service and no intercity HSGT service. Currently, the highway system 

within the Project Area is operating at or near capacity during commuting hours, especially within the 

metropolitan areas of Atlanta, Rome, Dalton, and Chattanooga (as reported by Transportation 

Demand Models for Atlanta Regional Commission (ARC), Greater Dalton MPO, ChattanoogaHamilton County Regional Planning Agency, and Rome-Floyd County MPOs 2013, and TDOT 

2014). Traffic congestion will persist in the future as a result of increasing passenger travel demand 

from population, tourism, employment, and business growth. 

Between the years 2000 and 2012, the population of Georgia increased 19 percent and the 

population of Tennessee increased 12 percent. The populations of 11 of the 16 counties within the 

Project Area during the same period grew by 10 percent or more including increases of 52 percent in 

Cherokee County and about 74 percent in Paulding County. The metropolitan Atlanta population is 

forecasted to increase from 5.4 million people in 2010 to 8.3 million by the year 2040 (ARC 2010).

Employment in the Project Area grew by over 40 percent from 1990 to 2012. ARC forecasts 

employment in metropolitan Atlanta will increase over 40 percent between 2010 and 2040, and the 

Chattanooga-Hamilton County Regional Planning Agency (CHCRPA) reports that employment is 

forecasted to increase 40 percent between 2007 and 2035.

The Georgia Interstate System Plan (GDOT 2004) reported that roadway travel demand along the 

majority of I-75, north of Atlanta, is projected to exceed capacity by 2030. Travel demand on US 41, 

US 411, and US 27, the other north-south routes between Atlanta and Chattanooga, is expected to 

equal or exceed capacity within the next 30 years notwithstanding planned highway improvement 

projects. Given the projected increases in travel demand throughout the Project Area, additional 

alternatives to address existing and future travel demand are needed. 

Therefore, to maintain and enhance the economic vitality of the two anchor cities and throughout the 

Project Area, the mobility of those traveling within the Project Area requires improvement. With 

greater regional mobility connections to Atlanta and Hartsfield-Jackson Atlanta International Airport 

(HJAIA), a connection to the national and global economy would be realized for Chattanooga and 

Northwest Georgia. 
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-3 September 2016

Figure 0-1: Project Area Map
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-4 September 2016

In this Tier 1 DEIS, FRA, GDOT, and TDOT are considering actions to address transportation needs 

stemming from increasing travel demand and forecast population and employment growth.

Specifically, the needs for the Project include:

 Enhance Regional Transportation Mobility and Accessibility

 Population and Employment Growth

 Congested Transportation Corridor with Increasing Demand

 Limited Transportation Options

 Spur Economic Growth and Regional Vitality

 Provide Safe, Efficient, Reliable Transportation

 Enhance Airport Access and Intermodal Connections

 Improve Air Quality Nonattainment Areas and Minimize Environmental Impacts

0.1.3 Corridor Alternatives Considered

0.1.3.1 Scoping

One of the initial steps the agencies took in preparing this Tier 1 DEIS was the development and 

implementation of a public involvement program and public scoping process to solicit issues, 

concerns, and ideas regarding a proposed HSGT Project and the corresponding assessment of 

environmental impacts in the Project vicinity. During the formal scoping process, the public, 

stakeholders, and government agencies provided input on the following subject areas:

 The Project’s purpose and need;

 Potential mode technologies;

 Potential proposed project corridors and station stop locations;

 The scope of the assessment of potential environmental impacts for the Project;

 Methodology for selecting the corridors for further study; and

 Opportunities for public involvement.

0.1.3.2 High Speed Ground Transportation Technologies

In the scoping process, several HSGT train technologies were identified. HSGT is a mode of 

transportation that can travel at greater speeds than traditional rail technology and can provide 

improved passenger mobility and reduce travel times in the Project Area. For the purposes of this 

proposed project, HSGT is defined as trains having the ability to travel at speeds at or above 180 

miles per hour (mph) and as an intercity passenger transportation mode that is time-competitive with 

air and highway travel for trips of 100 to 500 miles. The train technologies that were considered 

included: diesel multiple unit, commuter rail, intercity rail, “Low” High Speed Intercity Rail, and Very 

High Speed Rail (VHS), which consists of steel-wheeled and magnetic levitation (Maglev) 

technologies. 

0.1.3.3 Identification and Screening of Corridors

During the scoping process, GDOT identified 15 unique corridors extending from HJAIA to 

downtown Chattanooga. Following scoping, the 15 corridors were subjected to a screening process 

as part of the development process for the corridor alternatives. The screening process was 

undertaken to identify the reasonable corridor alternatives to be evaluated in this Tier 1 DEIS. The 
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-5 September 2016

screening process assessed the relative attributes of the potential HSGT corridors. The screening 

process included the following tasks:

 Development of measures of effectiveness (MOEs);

 Application of MOEs to assess how well each corridor meets the Project’s purpose and need. 

Screening sought to advance the best performing corridor(s) based on the criterion of 

transportation mobility; and

 Involvement of FRA, GDOT, TDOT, participating agencies, stakeholders, and the public in the 

screening process.

The Project Team (FRA, GDOT, and TDOT) advanced the three corridor alternatives listed below for 

further evaluation in the Tier 1 DEIS since they most closely met the Project purpose and need. The 

three Norfolk Southern (NS) corridors (I-75 Southern Crescent NS, East Southern Crescent NS, and 

I-75/Rome Southern Crescent NS) were also retained, but detailed analyses of the three NS 

corridors were deferred to future studies as design options for the Atlanta area:

 I-75 Southern Crescent;

 East Southern Crescent; and

 I-75/Rome Southern Crescent.

0.1.3.4 Alternatives Evaluated in this Tier 1 DEIS

Based on the results of screening (described in detail in Appendix B), the three corridors listed 

above were advanced in this Tier 1 DEIS to evaluate their potential environmental impacts. A NoBuild Alternative was also analyzed in this Tier 1 DEIS. Both the No-Build Alternatives and the 

Corridor Alternatives are described in the following sections. 

No-Build Alternative

Federal regulations require that a No-Build Alternative be evaluated in an EIS. The No-Build 

Alternative includes the existing transportation system and assumes that there would be no new 

HSGT improvements in the Project Area. The No-Build Alternative assumes that all transportation 

system improvements that are currently listed in local, regional, and state transportation plans and 

that have identified funds for implementation will be implemented. Thus, the No-Build Alternative 

represents the Project Area’s transportation system as it is anticipated to be in the planning horizon 

year 2040. The system includes highway and transit projects in each of the MPO’s transportation 

plans within the Project Area as well as aviation projects identified in the Master Plans of the two 

airports, HJAIA, and Chattanooga Metropolitan Airport (CMA), which currently provide passenger 

carrier service to the Project Area. The existing transportation system serving the Project Area can 

be summarized as follows:

 The highway system consists primarily of Interstate highways I-75, I-285, and I-24, and of 

highways US 27, US 411, and US 41. 

 The Intercity bus transit service is provided by Greyhound and Megabus. Regional bus transit 

service is provided within metropolitan Atlanta by Metropolitan Atlanta Rapid Transit Authority 

(MARTA), Cobb Community Transit (CCT), and Gwinnett County Transit (GCT). The Georgia 

Regional Transportation Authority (GRTA) provides regional commuter “Xpress” bus service. 

Local bus service is provided by the Chattanooga Area Regional Transportation Authority

(CARTA), MARTA, and the City of Rome Transit Department (RTD). MARTA also includes a 

48-mile heavy rail transit system with 38 stations within metropolitan Atlanta. 

 The aviation system consists of two airports that currently provide passenger carrier service to 

the region: HJAIA and CMA.
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-6 September 2016

Corridor Alternatives

Like the No-Build Alternative, the Corridor Alternatives also assume the implementation of the 

transportation system improvements that are currently listed in local, regional, and state 

transportation plans and that are funded for construction. The three corridors that advanced from the 

screening process to become Corridor Alternatives are I-75 Southern Crescent, East Southern 

Crescent, and I-75/Rome Southern Crescent as illustrated in Figure 2-16. To streamline the naming 

convention used in this Tier 1 DEIS, the phrase “Southern Crescent” will be omitted as it applies 

equally to all. 

For this Tier 1 DEIS, the Corridor Alternatives are examined within corridors 1,000 feet in width, 

which allows for variation in the horizontal alignments to be determined during the Tier 2 NEPA 

phase and is sufficiently wide to evaluate the potential environmental issues associated with the 

alternatives. No alignments have been defined in this Tier 1 DEIS. The vertical alignments, also to 

be determined during the Tier 2 NEPA phase, would vary along the corridors between at-grade, 

elevated structure, and tunnel, depending on the topographic conditions and existing development

within each corridor alternative. All Corridor Alternatives would be constructed as exclusive facilities 

that do not share track with other trains and are grade separated when crossing roadways or rail 

lines. 

In this Tier 1 DEIS, the Corridor Alternatives are considering both steel-wheeled and Maglev 

technologies. The potential station locations presented are conceptual and are intended to indicate 

general areas to be served by the alternative, not specific sites of stations. Exact locations of 

potential stations will be determined during the Tier 2 NEPA phase.

I-75 Corridor Alternative: The I-75 Corridor Alternative begins on the east side of HJAIA at the

proposed HJAIA/Southern Crescent (HJAIA/SC) station, immediately adjacent to I-75, and follows I75 to a point south of the proposed downtown Atlanta station. The corridor continues north 

underground through downtown Atlanta to I-75 north and uses the I-75 right-of-way (ROW) to the 

proposed Cumberland/Galleria station. It continues north along the I-75 ROW to the proposed Town 

Center, Cartersville, and Dalton stations. North of I-24 in Tennessee, the corridor continues along an 

existing CSX rail ROW to proposed stations at CMA and in downtown Chattanooga.

East Corridor Alternative: The East Corridor Alternative follows the same alignment as the I-75 

corridor to the proposed Cartersville station. North of the Cartersville station, the corridor deviates 

from I-75 and continues along existing CSX ROW generally parallel to US 411, stops at the DaltonChatsworth and CMA stations, and continues to the proposed downtown Chattanooga station.

I-75/Rome Corridor Alternative: The I-75/Rome Corridor Alternative follows the same path as the I75 and East corridors to the proposed Cartersville station. From the proposed Cartersville station, 

the corridor follows US 411 to Rome, continues north along an existing NS rail ROW to rejoin I-75 

between the proposed Cartersville and Dalton stations. The corridor continues north along the I-75 

ROW to the proposed stations at Dalton and CMA and in downtown Chattanooga.

Each of the Corridor Alternatives includes proposed areas for stations. Stations would provide parkand-ride facilities with direct pedestrian connections to the stations. The station type, configuration, 

and exact location of the proposed station will be developed during the Tier 2 NEPA phase if a 

Corridor Alternative is selected as a Preferred Alternative to be further evaluated. 
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-7 September 2016

Figure 0-2: Corridor Alternatives
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-8 September 2016

General areas for a potential storage, maintenance and inspection facility are identified in Figure 0-

2. Exact locations for the storage, maintenance and inspection facilities have not been identified nor 

were they evaluated in this Tier 1 DEIS. Storage yard capacity requirements would be based on the 

required fleet and the operating plan. For the purpose of this Tier 1 DEIS, it is assumed the 

proposed Project would include:

 A storage and heavy maintenance facility near the southern terminus in the vicinity of HJAIA. 

This facility also would include the command center for all systems and train wash facilities; and

 A storage and inspection yard near the northern terminus within the Chattanooga area. It would 

provide facilities for running inspections, light duty repairs on equipment, as needed, and train 

storage. This yard also would include a control tower to control access to and within the yard. 

Table 0-1 presents key attributes of each Corridor Alternative. 

Table 0-1: Corridor Alternatives Attribute Comparison

Corridor Alternative 

(Potential Number of 

stations)

Length of 

Alternative 

(miles)

Projected 2040 Total 

Daily Ridership*

(passengers)

Time to Travel 

Corridor End to End 

(minutes)

I-75 (8) 128 11,725 88

East (8) 139 8,556 95

I-75/Rome (9) 150 13,204 102

* Appendix D provides Travel Demand Modeling information.

0.2 Summary of Key Environmental Findings

The Tier 1 analysis of environmental consequences described in this chapter determined that the 

Project as well as the No-Build Alternative projects (see Section 0.1.3.4) have the potential to impact 

the human and natural environment. 

No-Build Alternative: The extent to which the projects in the No-Build Alternative would avoid or 

minimize impacts on the human and natural environment can only be determined through 

environmental analysis to be undertaken by the sponsors of those projects. Key findings of this Tier 

1 assessment are that the No-Build Alternative:

 Would increase capacity and expand service in selected portions of the Project Area 

transportation network, but would not enhance passenger mobility throughout the Project Area 

between the metropolitan areas and airports of Atlanta and Chattanooga; 

 Would not adequately address the transportation needs of projected population and employment 

growth in the Project Area, would not increase transportation options, would not increase airport 

and intermodal connections, would not fully address transportation limitations on economic 

growth, and would not provide faster and more reliable ground transportation service as an 

alternative to highway, intercity bus and air travel; 

 Would not improve air quality because it would not reduce the quantity or the growth rate of 

mobile source emissions resulting from vehicle miles traveled on the highway network in the 

Project Area; and

 Potentially would have impacts on communities, parks, wildlife refuges and recreational areas, 

cultural resources, water and biological resources.
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-9 September 2016

Corridor Alternatives: Key findings of the Tier 1 assessment are that the Corridor Alternatives:

 Would enhance regional mobility and accessibility in the Project Area; 

 Would help address the transportation needs of projected population and employment growth in 

the Project Area, particularly in terms of increasing transportation options, increasing airport 

access and intermodal connections, address transportation limitations on economic growth, and 

provide faster and more reliable ground transportation as an alternative to highway, intercity bus 

and air travel; 

 Would improve air quality by providing a transportation option that does not increase the quantity 

or the growth rate of mobile source emissions resulting from vehicle miles traveled on the 

highway network in the Project Area; and

 Potentially would have impacts on communities, parks, wildlife refuges and recreational areas, 

cultural resources, water and biological resources.

In regard to potential human and natural environment impacts, the Tier 1 analysis revealed several

differences among the Corridor Alternatives:

 Ridership: The I-75/Rome Corridor Alternative would have the highest ridership, followed by the 

I-75 Corridor Alternative; the East Corridor Alternative would have the lowest ridership.

 Travel time: End to end travel times vary among the Corridor Alternatives with the I-75 Corridor 

Alternative being the shortest at 88 minutes, the East Corridor Alternative at 95 minutes, and the 

I-75/Rome Corridor Alternative at 102 minutes.

 Transportation: The I-75 Corridor Alternative would use the most existing transportation ROW, 

followed by the I-75/Rome Corridor Alternative. The East Corridor Alternative would use the least 

existing transportation ROW, thereby having the highest potential for adverse effects according 

to this measure.

 Air quality: All Corridor Alternatives would result in reduced emissions. The I-75/Rome Corridor 

Alternative has the highest potential to transfer trips from the highway system to the HSGT and, 

thereby, reduce vehicular emissions. This finding is based solely on ridership. 

 Noise and Vibration: All Corridor Alternatives would have potential noise and vibration impact. 

The I-75 Corridor Alternative is the best performing for both noise and vibration sensitive land 

uses within their respective screening distances. This may be attributed to the fact that a longer

length of the I-75 Corridor Alternative is adjacent to the interstate highway system, whereas the 

other two alternatives deviate from the interstate and travel along U.S. highways (which tend to 

have more development located closer to the roadway than interstate highways).

 Population and Employment Access: County-based 2010 U.S. Census data demonstrate that 

the more urbanized areas typically have higher densities of minority and low-income populations 

compared with rural areas. The ratio of environmental justice (EJ) areas to non-EJ areas within 

each Corridor Alternative when measured by linear mile along each corridor is 0.6:1 for the I-75 

Corridor Alternative and 0.5:1 for the East and I-75/Rome Corridor Alternatives. Moreover, not all 

Corridor Alternatives serve the same proposed station locations or the same EJ populations. For 

example, only the I-75/Rome Corridor Alternative would serve the proposed Rome station area. 

Similarly, only the East Corridor Alternative would serve the proposed Dalton-Chatsworth station 

area. Therefore, depending on the Corridor Alternative, some EJ populations in the study area 

would be served and some would not.

 Parklands and wildlife refuges: The difference between the Corridor Alternatives in terms of total 

acreage of potentially affected parkland and wildlife refuges is insignificant; however, there is 

distinguishable difference in the number of individual parks or refuges that could be affected. 
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-10 September 2016

The I-75/Rome Corridor has the highest number of potential parklands that could be affected

and the East Corridor has the least.

 Historic resources: The East Corridor Alternative has twice the number of known historic 

resources as the I-75 or I-75/Rome Corridor Alternatives. The higher number is due to the East 

Corridor Alternative using a lower percentage of existing transportation rights-of-way. This 

differentiating factor suggests the potential for a higher number of Project impacts on known 

historic resources if the East Corridor Alternative is advanced.

 Wetlands, streams and floodplains: The I-75/Rome Corridor Alternative has more acres of 

wetlands and stream crossings than the other Corridor Alternatives. This difference suggests the 

potential for a higher number of Project impacts on wetlands and streams if the I-75/Rome 

Corridor Alternative is advanced. The East Corridor Alternative has a considerably higher 

acreage of floodplains compared with the other alternatives.

 Known threatened and endangered species habitats: The East Corridor Alternative has a larger 

number of known threatened and endangered species habitats than the I-75 and I-75/Rome 

Corridor Alternatives. This differentiating factor suggests the potential for a higher number of 

Project impacts on known threatened and endangered species habitats if the East Corridor

Alternative is advanced.

Table 0-2 summarizes the data findings for the Corridor Alternatives; these data are discussed in the 

remaining sections of this chapter.

In summary, despite the differences among the Corridor Alternatives, each Corridor Alternative 

demonstrates some level of achievement of the Project purpose based on the data available at this 

Tier 1 level of study and shown in Table 0-2. The East Corridor Alternative has the highest potential 

for impacts on known historic resources and floodplains, while the I-75/Rome Corridor Alternative 

has the highest potential to impact wetlands and stream crossings. Compared to the other Corridor 

Alternatives, the I-75 Corridor Alternative has the lowest potential for impact on known historic 

resources, streams, and floodplains; impacts on wetlands are similar to the East Corridor Alternative.
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-11 September 2016

Table 0-2: Comparative Summary of the Corridor Alternatives

Needs Measures Corridor Alternative

I-75 East I-75/Rome 

Enhance regional 

transportation mobility 

and accessibility

Time to Travel Alternative End 

to End (minutes) 88 95 102

Population within 10 miles of 

Proposed Station Locations 

(millions)

2.85 2.86 2.95

Employment within 5 Miles of 

Proposed Station Locations 

(thousands)

869 870 894

Daily Ridership 

(number of boardings) 11,725 8,556 13,204

Spur economic growth 

and regional vitality Capital Cost (2014$ millions) $8,760 $10,420 $9,811

Provide safe, efficient, 

reliable transportation

Provide passenger HSGT 

service on exclusive guideway Yes Yes Yes

Enhance airport 

access and intermodal 

connections

Provide access to HJAIA and 

CMA; connect to MARTA, 

GRTA and CCT service areas

Yes Yes Yes

Improve air quality 

nonattainment areas 

and minimize 

environmental impacts

Proportion of Corridor 

Alternative within Existing 

Transportation Corridor 

(percent)

76% 31% 53%

Ratio of EJ areas to overall 

corridor (based on linear miles) 0.6:1 0.5:1 0.5:1

Noise-sensitive Land Uses 

(acres) 5,914 7,519 8,425

Vibration-sensitive Land Uses 

(acres) 891 1,695 1,372

Ratio of Station Areas with and 

without EJ populations 6:2 6:2 6:2

Parklands and Wildlife Refuges 

(acres)

443 447 442

Parklands and Wildlife Refuges 

(number) 25 19 30

Known Archaeological 

Resources (number) 32 46 38

Known Historic Resources 

(number) 26 66 33

Cemeteries (number) 4 3 5

Wetlands (acres) 205 205 251

Stream Crossings (number) 21 18 35

Floodplains (acres) 1,563 2,576 1,689

Known Threatened and 

Endangered Species Habitats 

(number)

21 38 21

Known Threatened and 

Endangered Species Habitats 

(acres)

1,907 2,158 1,817

0.3 Evaluation of Alternatives

GDOT and TDOT have striven to avoid or minimize effects during Tier 1 analysis by aligning the 

Corridor Alternatives primarily along existing transportation corridors as opposed to creating wholly 

new corridors. The buffer areas provide opportunities to avoid or minimize impacts in future design.

Yet some potential effects may not be avoidable given the developed character of some 

communities the Project is intended to serve, the design requirements of the Project, and the need 

to avoid adversely affecting future operations of the existing transportation facilities. Consequently, 
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-12 September 2016

the decision to advance one alternative to the next phase of study involves recognizing and 

understanding that GDOT and TDOT are working to balance the trade-offs between the benefits and 

effects of the alternatives. 

Each Corridor Build Alternative would enhance intercity mobility and economic growth throughout 

the Project Area by providing safe, cost-effective, faster and more reliable high-speed ground 

transportation service between Atlanta, Georgia and Chattanooga, Tennessee. The high-speed 

ground transportation service provided by each Corridor Build Alternative would be competitive with 

existing highway, intercity bus, or air travel within the Project Area and each Corridor Build 

Alternative would avoid, minimize, and mitigate impacts on the human and natural environment. The 

extent to which each Corridor Alternative meets the Project purpose varies, as indicated in Table 0-

3, which focuses on the 12 distinguishing performance measures. Table 0-3 compares how each 

Corridor Alternative performs with regard to the measures and identifies which of the three Corridor 

Alternatives are the best-performing, moderately-performing, and worst-performing with regard to 

each measure. The following describes the ratings assigned for each type of measure:

 A “Best-Performing Corridor Alternative” rating is associated with the fewest impacts

(expressed in number and acreages), the shortest travel times, the lowest capital costs, and 

the highest daily ridership and proportion of the corridor alternative within an existing 

transportation corridor.

 A “Worst-Performing Corridor Alternative” rating is associated with the most impacts, the 

longest travel times, the highest capital costs, and the lowest daily ridership and proportion 

of the corridor alternative within an existing transportation corridor.

 A “Moderately-Performing Corridor Alternative” rating is associated with quantities of 

impacts, travel times, capital costs, daily ridership, and proportion of the corridor alternative 

within an existing transportation corridor between those quantities exhibited by the “HighestPerforming Corridor Alternative” and “Lowest-Performing Corridor Alternative” for that 

particular measure. 

Table 0-3: Summary of Distinguishing Performance Measures

Needs Measures Corridor Alternative

I-75 East I-75/Rome 

Enhance regional 

transportation mobility 

and accessibility

Time to Travel Corridor Alternative End 

to End (minutes) 88 95 102

Daily Ridership (number of boardings) 11,725 8,556 13,204

Spur economic growth 

and regional vitality Capital Cost (2014$ millions) $8,760 $10,420 $9,811

Minimize environmental

impacts

Proportion of Corridor Alternative within 

Existing Transportation Corridor 76% 31% 53%

Noise-sensitive Land Uses (acres) 5,914 7,519 8,425

Vibration-sensitive Land Uses (acres) 891 1,695 1,372

Known Historic Resources (number) 26 66 33

Wetlands (acres) 205 205 251

Stream Crossings (number) 21 18 35

Floodplains (acres) 1,563 2,576 1,689

Parks & Wildlife Refuges (number) 25 19 30

Known Threatened and Endangered 

Species Habitats (number) 21 38 21

Notes:

 Best-Performing Corridor Alternative

 Moderately-Performing Corridor Alternative

 Worst-Performing Corridor Alternative
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-13 September 2016

The I-75 Corridor Alternative is the Best-Performing Corridor Alternative overall. It rates as the BestPerforming Corridor Alternative for most performance measures, including travel time, capital cost, 

use of existing transportation corridors, potential noise and vibration impacts, and potential impacts 

to known historic resources, wetlands, floodplains, and known threatened and endangered species 

habitats. It is the Moderately-Performing Corridor Alternative for ridership and stream crossings. The 

I-75 Corridor Alternative is not rated as the Worst-Performing Corridor Alternative for any of the 

distinguishing measures.

The East Corridor Alternative rates as the Best-Performing Corridor Alternative in terms of potential 

impacts on wetlands and stream crossings, and rates as the Moderately-Performing Corridor 

Alternative with regard to travel time and potential impacts to known threatened and endangered 

species habitats. The East Corridor Alternative has more noise-sensitive land uses than the I-75 

Corridor Alternative, and it has the most vibration-sensitive land uses of the three Corridor 

Alternatives. The East Corridor Alternative performs least well among the Corridor Alternatives in the 

areas of ridership, capital cost, and potential impacts to known historic resources and floodplains.

The I-75/Rome Corridor Alternative rates as the Best-Performing Corridor Alternative for ridership 

and potential impacts to known threatened and endangered species habitats. It rates as the 

Moderately-Performing Corridor Alternative with regard to use of existing transportation corridors 

and potential impacts to known historic resources and it rates as the Worst-Performing Corridor 

Alternative for travel time, potential noise impacts, and potential impacts to wetlands and stream 

crossings.

The No-Build Alternative projects would provide some improvements in roadway and transit 

operations within the Project Area, by increasing capacity and expanding service in selected portions 

of the Project Area transportation network. It is reasonable to expect that these planned 

improvements would reduce travel time and congestion of roadways in the Project Area, and 

increase transit ridership where new or expanded transit services are proposed. However, none of 

the No-Build Alternative projects alone or in aggregate will enhance passenger mobility throughout 

the Project Area between the metropolitan areas and airports of Atlanta and Chattanooga as 

specified in the Project purpose. For this reason, the No-Build Alternative does not achieve the 

Project purpose. 

The projects in the No-Build Alternative would incur costs and potential effects on the human and 

natural environment that would be determined by the sponsors of those projects. As the geographic 

scope and nature of the No-Build Alternative projects is limited, the potential effects of the projects 

are likely to be limited. Thus, the No-Build Alternative has the potential to cause fewer effects on the 

human and natural environment than the Corridor Alternatives.

The findings of this analysis indicate that the decision to be made by the Tier 1 Final EIS/Record of 

Decision (ROD) involves examining the trade-offs between the benefits and potential effects of the 

Corridor and No-Build Alternatives. Given the use of 1,000 feet wide study areas for the Corridor 

Alternatives, opportunity exists to avoid or minimize effects on the human and natural environment 

as the Project advances in Tier 2 NEPA analysis. Because most environmental impacts can be 

reasonably avoided/minimized, cost-effectiveness criteria provide a more distinguishing comparison 

between alternatives at the corridor level.

If a Corridor Alternative is selected, FRA, GDOT, and TDOT would work to preserve existing and 

planned transportation operations in the existing corridors they affect as well as avoid or minimize 

impacts on the human and natural environments. If a Corridor Alternative is selected, GDOT and 

TDOT will coordinate with regulatory agencies in Tier 2 to identify and refine alignments that avoid or 

minimize adverse effects. Likewise in the Tier 2 phase of the project, GDOT and TDOT will work with 

affected stakeholders and the communities to avoid or minimize adverse effects of alignments they 

develop during Tier 2 study.
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-14 September 2016

0.4 Coordination with Agencies, Stakeholders, and the Public 

In accordance with the Agency and Stakeholder Involvement Plan (ASIP) (GDOT 2014) and 

SAFETEA-LU requirements, between 2007 and 2013, GDOT and TDOT held meetings with 

participating agencies, Project stakeholders, and the public. The outcome of these meetings 

indicated support by attendees for the construction and operation of the Project. Public involvement 

activities were ongoing throughout the process and included the following:

Agency Scoping - The environmental planning and review process for the Project began with early 

coordination and an agency scoping process with participating agencies, which are defined by 

SAFETEA-LU as those with an interest in the Project. A list of participating agencies for the Project 

is provided in Appendix E - Agency Coordination and Public Outreach. The Project Team, which 

includes GDOT and TDOT, decided to defer the identification of cooperating agencies to the Tier 2 

NEPA phase when a corridor alternative is selected. The scoping process began on August 22, 

2007 and ended on October 4, 2007 during which two Agency Scoping Meetings were held. The 

scoping process was used to identify the range of mode technologies and corridors to be studied, 

the potential impacts to the human and natural environments, and the issues and concerns to be 

addressed in the Tier 1 analysis. 

Interagency Coordination –GDOT and TDOT held meetings between federal and state lead 

agencies on a monthly basis. These meetings provided opportunity for ongoing coordination and 

discussion of the Project process, products, and issues. In addition, GDOT and TDOT held meetings 

with participating agencies to review the key Tier 1 NEPA milestones. Participating agencies were 

involved in, and participated in, the review of the Project’s purpose and need; the identification of the 

potential corridors and mode technologies; the corridor alternative screening and corridor alternative 

development; and the scope of the environmental impact assessment of the Tier 1 DEIS. GDOT and 

TDOT conducted agency coordination periodically between 2011 and 2013.

HSGT Steering Committee - This is a sub-committee of the Georgia State Transportation Board’s 

Intermodal Committee (the Georgia Board) that supported the development of the Tier 1 DEIS. 

GDOT and TDOT provided regular briefings to the Steering Committee throughout the development 

of this Tier 1 DEIS. The Steering Committee also provided input to GDOT and TDOT project 

management staff at key points. 

Native American Tribes – Since Native American Tribes may have interests regarding natural and 

cultural resources that could be in the Project Area, during the Scoping Process in 2007, GDOT 

contacted potentially affected tribes and the Georgia Natural Heritage Program (GNHP) via letter to 

notify them of the Project and to invite them to participate in the planning process. GDOT and TDOT 

will continue to coordinate with Native American Tribes and GNHP throughout Project development2.

Stakeholders - GDOT and TDOT engaged stakeholders, identified as any agency, organization, or 

group with an interest in the Project, but not designated as a participating agency, on an ongoing 

basis to provide timely and ongoing feedback. 

In the early stages of the Tier 1 DEIS between January and June 2008, local government 

stakeholders were involved in 19 meetings held with local planning and technical staff in the Project 

Area. More than 60 local government representatives participated. From July to September 2008 

over 20 stakeholder meetings were held with community, neighborhood, and business organizations. 

To support the corridor screening and alternative development process, nine additional stakeholder 

meetings were held in October and November 2010. 

 

2

The coordination should not be considered full consultation under Section 106 of the National Historic Preservation Act. Section 

106 consultation will be conducted during the Tier 2 NEPA phase.
Executive Summary

Atlanta-Chattanooga HSGT Tier 1 DEIS 0-15 September 2016

Public Involvement - There have been two major decision points where significant involvement from 

the public was solicited: 

 In 2007, Public Scoping Meetings were held in three different locations during September to 

develop the purpose and need, and the range of potential corridors and mode technologies to be 

evaluated in the Tier 1 DEIS. These Public Scoping Meetings were advertised in local 

newspapers such as the Atlanta Journal Constitution, the Rome-News Tribune, the Daily 

Tribune-News of Cartersville, and the Chattanooga Times-Free Press. Meetings were also 

announced on the Project website (https://www.dot.ga.gov/travelingingeorgia/rail/Pages/AtlChatt.aspx); and

 In 2010, Public Information Open House Meetings were held in four different locations in 

November to review the corridor screening and alternative development process and results. 

Advertisement for the public information open house meetings appeared on the Project website 

and the GDOT website, a Project flyer was distributed to those listed in the contact database, 

and notices were sent to chambers of commerce and other agencies in the Project Area. Public 

service announcements were sent to local radio stations and meeting announcements were sent 

to online calendars. Press releases were distributed to GDOT’s media contact list. The chambers 

of commerce in each city assisted in promoting the meetings by distributing flyers by email and 

posting on their websites. 

In accordance with NEPA and FRA’s procedures, once the Tier 1 DEIS is made available for public 

review, there will be a minimum 45 day public comment period. During that time, FRA, GDOT and 

TDOT will hold a public meeting to provide interested parties to learn more about the Project, submit 

comments on the Project, and obtain feedback from the Project team on the Tier 1 DEIS. After the 

close of the meeting and public comment period, FRA, GDOT and TDOT will consider the public and 

agency input as well as the findings of the Tier 1 DEIS. 

0.5 Next Steps

After FRA publishes the Tier 1 DEIS and the public comment period is completed, GDOT and TDOT 

will prepare a combined Tier 1 Final EIS (FEIS) and Record of Decision (ROD) wherein the 

Preferred Corridor Alternative will be identified.

3

FRA will sign the combined FEIS/ROD, thereby 

selecting the Preferred Corridor Alternative. Should funding for further study become available, FRA, 

GDOT, and TDOT will then evaluate potential alignments configurations within the Preferred 

Corridor Alternative in the Tier 2 NEPA process.

Since there will be no selection of a preferred technology as part of this Tier 1 DEIS, both Maglev 

and steel-wheel technologies would advance for consideration with the Preferred Corridor 

Alternative. When a technology is selected, the selected alignment will be refined to optimize the 

operation of the selected technology.

 

3 Pursuant to Pub. L. 112-141, 126 Stat. 405, Section 1319(b), FRA will issue a combined FEIS/ROD, unless FRA determines that 

statutory criteria or practicability considerations preclude issuance of such a combined document.
Table of Contents

Atlanta-Chattanooga HSGT Tier 1 DEIS i September 2016

Table of Contents

0.0 EXECUTIVE SUMMARY.................................................................................................................. 0-1

0.1 Overview ...................................................................................................................0-1

0.1.1 Project Area Description ............................................................................0-1

0.1.2 Purpose and Need .....................................................................................0-2

0.1.3 Corridor Alternatives Considered...............................................................0-4

0.2 Summary of Key Environmental Findings ............................................................0-8

0.3 Evaluation of Alternatives.................................................................................... 0-11

0.4 Coordination with Agencies, Stakeholders, and the Public ............................ 0-14

0.5 Next Steps.............................................................................................................. 0-15

1.0 PURPOSE AND NEED FOR ACTION............................................................................................ 1-1

1.1 Introduction ..............................................................................................................1-1

1.2 Tiering Process ........................................................................................................1-2

1.3 Project Background and Planning History ...........................................................1-2

1.4 Purpose.....................................................................................................................1-6

1.5 Needs.........................................................................................................................1-6

1.5.1 Enhance Regional Transportation Mobility and Accessibility ....................1-6

1.5.2 Enhance Airport Access and Intermodal Connections ........................... 1-12

1.5.3 Spur Economic Growth and Vitality ........................................................ 1-13

1.5.4 Provide Safe, Efficient, Reliable Transportation ..................................... 1-14

1.5.5 Improve Air Quality Nonattainment Areas and Minimize Environmental 

Impacts .................................................................................................... 1-14

1.6 Project Goals and Objectives .............................................................................. 1-14

1.6.1 Improve Regional Mobility....................................................................... 1-15

1.6.2 Support and Ensure Consistency with National, State, and Local 

Transportation Planning Initiatives.......................................................... 1-15

1.6.3 Avoid or Minimize Environmental Impacts.............................................. 1-17

1.6.4 Promote Financial and Economic Growth............................................... 1-18

2.0 ALTERNATIVES CONSIDERED..................................................................................................... 2-1

2.1 Scoping .....................................................................................................................2-1

2.1.1 High Speed Ground Transportation Train Technologies ...........................2-1

2.1.2 HSGT Segments and Corridors .................................................................2-6

2.2 Corridor Screening Process and Results .......................................................... 2-20

2.3 Definition of Alternatives ..................................................................................... 2-22

2.3.1 No-Build Alternative................................................................................. 2-22

2.3.2 Corridor Alternatives................................................................................ 2-25

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES............................. 3-1

3.1 Introduction ..............................................................................................................3-1

3.2 Summary of Key Findings.......................................................................................3-2
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Atlanta-Chattanooga HSGT Tier 1 DEIS ii September 2016

3.3 Transportation..........................................................................................................3-5

3.3.1 Legal and Regulatory Context....................................................................3-5

3.3.2 Methodology...............................................................................................3-5

3.3.3 Affected Environment.................................................................................3-6

3.3.4 Environmental Consequences ................................................................ 3-13

3.3.5 Potential Mitigation.................................................................................. 3-17

3.3.6 Subsequent Analysis............................................................................... 3-18

3.4 Air Quality .............................................................................................................. 3-19

3.4.1 Legal and Regulatory Context................................................................. 3-19

3.4.2 Methodology............................................................................................ 3-21

3.4.3 Affected Environment.............................................................................. 3-21

3.4.4 Environmental Consequences ................................................................ 3-22

3.4.5 Potential Mitigation.................................................................................. 3-22

3.4.6 Subsequent Analysis............................................................................... 3-23

3.5 Noise and Vibration .............................................................................................. 3-23

3.5.1 Legal and Regulatory Context................................................................. 3-23

3.5.2 Methodology............................................................................................ 3-23

3.5.3 Affected Environment.............................................................................. 3-25

3.5.4 Environmental Consequences ................................................................ 3-26

3.5.5 Potential Mitigation.................................................................................. 3-27

3.5.6 Subsequent Analysis............................................................................... 3-28

3.6 Socioeconomics and Environmental Justice .................................................... 3-28

3.6.1 Legal and Regulatory Context................................................................. 3-29

3.6.2 Methodology............................................................................................ 3-29

3.6.3 Affected Environment.............................................................................. 3-30

3.6.4 Environmental Consequences ................................................................ 3-37

3.6.5 Potential Mitigation.................................................................................. 3-39

3.6.6 Subsequent Analysis............................................................................... 3-40

3.7 Parklands, Wildlife Refuges, and Recreation Areas ......................................... 3-41

3.7.1 Legal and Regulatory Context................................................................. 3-41

3.7.2 Methodology............................................................................................ 3-41

3.7.3 Affected Environment.............................................................................. 3-42

3.7.4 Environmental Consequences ................................................................ 3-42

3.7.5 Potential Mitigation.................................................................................. 3-47

3.7.6 Subsequent Analysis............................................................................... 3-47

3.8 Cultural Resources ............................................................................................... 3-47

3.8.1 Legal and Regulatory Context................................................................. 3-48

3.8.2 Methodology............................................................................................ 3-49

3.8.3 Affected Environment.............................................................................. 3-50

3.8.4 Environmental Consequences ................................................................ 3-60

3.8.5 Potential Mitigation.................................................................................. 3-62

3.8.6 Subsequent Analysis............................................................................... 3-62
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Atlanta-Chattanooga HSGT Tier 1 DEIS iii September 2016

3.9 Water Resources................................................................................................... 3-63

3.9.1 Legal and Regulatory Context................................................................. 3-63

3.9.2 Methodology............................................................................................ 3-65

3.9.3 Affected Environment.............................................................................. 3-65

3.9.4 Environmental Consequences ................................................................ 3-76

3.9.5 Potential Mitigation.................................................................................. 3-78

3.9.6 Permits .................................................................................................... 3-79

3.9.7 Subsequent Analysis............................................................................... 3-80

3.10 Biological Resources ........................................................................................... 3-80

3.10.1 Legal and Regulatory Context................................................................. 3-80

3.10.2 Methodology............................................................................................ 3-81

3.10.3 Affected Environment.............................................................................. 3-82

3.10.4 Environmental Consequences ................................................................ 3-92

3.10.5 Potential Mitigation.................................................................................. 3-93

3.10.6 Subsequent Analysis............................................................................... 3-93

3.11 Secondary and Cumulative Effects..................................................................... 3-94

3.11.1 Legal and Regulatory Context................................................................. 3-94

3.11.2 Methodology............................................................................................ 3-94

3.11.3 Potential for Secondary and Cumulative Effects .................................... 3-95

4.0 PRELIMINARY SECTION 4(F) EVALUATION .............................................................................. 4-1

4.1 Summary Statement ................................................................................................4-1

4.2 Methodology.............................................................................................................4-1

4.3 Legal and Regulatory Context................................................................................4-1

4.4 Affected Environment..............................................................................................4-2

4.4.1 Section 4(f) Properties ...............................................................................4-2

4.5 Potential Uses of Section 4(f) Properties..............................................................4-4

4.6 Avoidance Analysis, Least Overall Harm Analysis, and All Possible Planning to 

Minimize Harm..........................................................................................................4-4

4.7 Preliminary Coordination........................................................................................4-5

4.8 Preliminary Section 4(f) Approvals and Subsequent Analysis...........................4-5

5.0 COSTS AND FUNDING.................................................................................................................... 5-1

5.1 Introduction ..............................................................................................................5-1

5.2 Estimated Capital Costs..........................................................................................5-1

5.3 Operating and Maintenance Costs.........................................................................5-3

5.4 Estimated Operating Revenues..............................................................................5-3

5.5 Potential Funding Sources .....................................................................................5-3

5.5.1 Funding Sources and Strategies for Operating Support............................5-5

5.5.2 Federal and State Capital Funding Assumptions and Requirements........5-7

5.6 Risk and Uncertainty ...............................................................................................5-8

5.6.1 Risk Assessment........................................................................................5-8
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Atlanta-Chattanooga HSGT Tier 1 DEIS iv September 2016

5.7 Summary of Funding Analysis ............................................................................ 5-10

5.8 Subsequent Analysis............................................................................................ 5-10

6.0 EVALUATION OF ALTERNATIVES............................................................................................... 6-1

6.1 Introduction ..............................................................................................................6-1

6.2 Effectiveness in Meeting the Purpose and Need .................................................6-2

6.2.1 Enhance Intercity Mobility ..........................................................................6-2

6.2.2 Enhance Economic Growth........................................................................6-2

6.2.3 Faster and More Reliable Ground Transportation Service........................6-3

6.2.4 Safe and Cost-Effective Transportation Service........................................6-3

6.2.5 Avoid or Minimize and Mitigate Impacts on the Human and Natural 

Environment ...............................................................................................6-5

6.3 Balancing Benefits and Effects..............................................................................6-7

6.4 Next Steps.................................................................................................................6-9

7.0 COORDINATION WITH AGENCIES, STAKEHOLDERS, AND THE PUBLIC........................... 7-1

7.1 Coordination Plan ....................................................................................................7-1

7.2 Agency Coordination and Consultation................................................................7-1

7.2.1 Agency Scoping .........................................................................................7-2

7.2.2 Interagency Coordination Meetings ...........................................................7-3

7.2.3 HSGT Intermodal Sub-Committee .............................................................7-3

7.3 Tribal Coordination..................................................................................................7-3

7.4 Stakeholder Involvement ........................................................................................7-3

7.4.1 Spring 2008 Stakeholder Meetings............................................................7-4

7.4.2 Fall 2010 Stakeholder Meetings ................................................................7-5

7.5 Public Involvement ..................................................................................................7-6

7.5.1 Fall 2007 Public Scoping Meetings............................................................7-7

7.5.2 Fall 2010 Public Information Open House Meetings .................................7-8

7.6 Public Meetings........................................................................................................7-9

7.7 Communication Tools .............................................................................................7-9

7.7.1 Stakeholder Contact Database ............................................................... 7-10

7.7.2 Project Website and Email...................................................................... 7-10

7.7.3 Newsletters.............................................................................................. 7-10

7.7.4 Media Relations....................................................................................... 7-10

7.7.5 Comment Forms...................................................................................... 7-10

7.7.6 Accommodations for Minority, Low-income, and Persons with Disabilities.7-

10

8.0 REFERENCES AND BIBLIOGRAPHY........................................................................................... 8-1

9.0 ACRONYMS...................................................................................................................................... 9-1

10.0 GLOSSARY OF TERMS................................................................................................................ 10-1

11.0 LIST OF PREPARERS................................................................................................................... 11-1
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Atlanta-Chattanooga HSGT Tier 1 DEIS v September 2016

List of Tables

Table 0-1: Corridor Alternatives Attribute Comparison.......................................................................0-8

Table 0-2: Comparative Summary of the Corridor Alternatives .......................................................0-11

Table 0-3: Summary of Distinguishing Performance Measures.......................................................0-12

Table 1-1: Project Area Population Growth 1990 to 2012..................................................................1-7

Table 1-2: Project Area Employment Growth 1990 to 2012...............................................................1-8

Table 1-3: LOS on Major Routes in the Project Area (2010 and 2040) .............................................1-9

Table 1-4: Economic Impact of Tourism in Georgia and Tennessee 2011 compared to 2010 .......1-13

Table 2-1: Travel Times by Train Technology and Transportation Mode ..........................................2-5

Table 2-2: HSGT Project Corridors and Potential Station Locations Considered..............................2-9

Table 2-3: Corridor Screening Criteria Scoring and Rating System.................................................2-20

Table 2-4: Corridor Screening Results – Summary of Corridor Performance..................................2-21

Table 2-5: Highway Projects.............................................................................................................2-23

Table 2-6: Transit Projects................................................................................................................2-24

Table 2-7: Aviation Projects..............................................................................................................2-24

Table 2-8: Corridor Alternatives Attribute Comparison.....................................................................2-27

Table 2-9: Characteristics of the Southern Crescent Corridors .......................................................2-28

Table 3-1: Comparative Summary of the Corridor Alternatives .........................................................3-4

Table 3-2: Roadways that Generally Parallel the Corridor Alternatives............................................3-6

Table 3-3: Level of Service on Major Routes in the Project Area (2010 and 2040)...........................3-7

Table 3-4: Proportion of Corridor Alternative within Existing ROW..................................................3-14

Table 3-5: Ridership and HSGT Travel Time ...................................................................................3-17

Table 3-6: National Ambient Air Quality Standards (NAAQS) for Criteria Pollutants.......................3-20

Table 3-7: Monitored Ambient Air Quality in the Project Area..........................................................3-21

Table 3-8: FRA Noise-Sensitive Land Use Categories and Metrics for High-Speed Train Noise ...3-24

Table 3-9: FRA Ground Borne Vibration Impact Criteria..................................................................3-25

Table 3-10: Noise-Sensitive Land Use Acreage Within Screening Distance by Alternative............3-25

Table 3-11: Vibration-Sensitive Land Use Acreage Within Screen Distance by Alternative ...........3-26

Table 3-12: Overall Project Area Population Growth by County 2000-2012....................................3-32

Table 3-13: Project Area Employment Growth 1990 to 2012...........................................................3-32

Table 3-14: Project Area Income and Poverty Status by County.....................................................3-35

Table 3-15: Number by Corridor of Census Tracts with High Concentrations of Environmental Justice 

Populations in the 1,000-foot Study Area (2010).....................................................3-35

Table 3-16: Population and Employment near the Proposed Stations ............................................3-38

Table 3-17: Parklands, Wildlife Refuges, and Recreation Areas within the Project Area................3-44

Table 3-18: Historic Resources Listed on the NRHP .......................................................................3-50
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Atlanta-Chattanooga HSGT Tier 1 DEIS vi September 2016

Table 3-19: Historic Resources Potentially Eligible for Listing on the NRHP...................................3-51

Table 3-20: Identified Archaeological Sites by NRHP Status...........................................................3-52

Table 3-21: Identified Cemeteries Potentially Eligible for Listing on the NRHP...............................3-52

Table 3-22: Summary of Identified Cultural Resources....................................................................3-61

Table 3-23: Water Resources in the Project Area............................................................................3-66

Table 3-24: Waters Classified in Regulations...................................................................................3-75

Table 3-25: Threatened and Endangered Species Habitat by County ............................................3-84

Table 3-26: Threatened and Endangered Species Habitats ............................................................3-93

Table 3-27: Potential Secondary Effects of the Corridor Alternatives..............................................3-96

Table 3-28: Potential Cumulative Effects of the Corridor Alternatives .............................................3-98

Table 4-1: Numbers of Section 4(f) Properties with 1,000-foot Buffer of Corridor Alternatives .........4-2

Table 5-1: Estimated Capital Costs ....................................................................................................5-2

Table 5-2: Estimated Annual Operating Revenue for the Year 2040.................................................5-3

Table 5-3: Federal, State, and Local Funding and Financing Sources..............................................5-4

Table 5-4: Potential HSGT Project Challenges ..................................................................................5-9

Table 6-1: Comparative Summary of the Corridor Alternatives .........................................................6-1

Table 6-2: Cost-effectiveness Comparison ........................................................................................6-4

Table 6-3: Race, Population and Employment in Proposed Station Areas........................................6-6

Table 6-4: Summary of Distinguishing Performance Measures.........................................................6-8

Table 7-1: Agency Scoping Meetings.................................................................................................7-2

Table 7-2: Spring 2008 Stakeholder Meetings ...................................................................................7-5

Table 7-3: Fall 2010 Stakeholder Meetings........................................................................................7-6

Table 7-4: Fall 2007 Public Scoping Meetings ...................................................................................7-7

Table 7-5: Fall 2010 Public Information Open House Meetings.........................................................7-8

Table 7-6: Public Information Open House Advertisement ................................................................7-9

List of Figures

Figure 0-1: Project Area Map..............................................................................................................0-3

Figure 0-2: Corridor Alternatives.........................................................................................................0-7

Figure 1-1: Project Area Map..............................................................................................................1-4

Figure 1-2: Roadway Level of Service (LOS) and Average Daily Traffic (ADT) – South.................1-10

Figure 1-3: Roadway Level of Service (LOS) and Average Daily Traffic (ADT) – North .................1-11

Figure 1-4: USDOT High Speed Intercity Passenger Rail Program.................................................1-16

Figure 2-1: Diesel Multiple Unit...........................................................................................................2-2

Figure 2-2: Diesel Steel-Wheel Metra Commuter Rail, Chicago, Illinois............................................2-3

Figure 2-3: Diesel – Electric Steel-Wheel Amtrak Train set, Northeast Corridor...............................2-3
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Atlanta-Chattanooga HSGT Tier 1 DEIS vii September 2016

Figure 2-4: Electric Steel-wheel Train, Alta Velocidad Espanola (AVE), Toledo, Spain....................2-4

Figure 2-5: The Shanghai Transrapid Maglev Train...........................................................................2-5

Figure 2-6: Segments .........................................................................................................................2-8

Figure 2-7: I-75 Terminal I-285, I-75 Southern Crescent NS, I-75 Southern Crescent Corridor .....2-11
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Atlanta-Chattanooga HSGT Tier 1 DEIS viii September 2016

Figure 2-8: 

East Terminal I-285, East Southern Crescent NS, East Southern Crescent Corridor 2-

11
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Atlanta-Chattanooga HSGT Tier 1 DEIS ix September 2016

Figure 2-9: 

I-75/West Corridor....................................................................................................2-12
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Atlanta-Chattanooga HSGT Tier 1 DEIS x September 2016

Figure 2-10: 

I-75/Rome Split Corridor ..........................................................................................2-13
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Atlanta-Chattanooga HSGT Tier 1 DEIS xi September 2016

Figure 2-11: 

I-75/Rome Terminal I-285, I-75/Rome Southern Crescent NS, I-75/Rome Southern 

Crescent Corridor.....................................................................................................2-14
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Atlanta-Chattanooga HSGT Tier 1 DEIS xii September 2016

Figure 2-12: West Corridor ...............................................................................................................2-16

Figure 2-13: West Connector Corridor..............................................................................................2-17
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Atlanta-Chattanooga HSGT Tier 1 DEIS xiii September 2016

Figure 2-14: 

West/East Corridor...................................................................................................2-17
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Atlanta-Chattanooga HSGT Tier 1 DEIS xiv September 2016

Figure 2-15: 

West/East Connector Corridor.................................................................................2-18

Figure 2-16: Corridor Alternatives.....................................................................................................2-26
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Atlanta-Chattanooga HSGT Tier 1 DEIS xv September 2016

Figure 3-1: Roadway Level of Service and Average Daily Traffic – South ........................................3-8

Figure 3-2: Roadway Level of Service and Average Daily Traffic – North.........................................3-9

Figure 3-3: Railroad Alignments within the HSGT Project Area.......................................................3-12

Figure 3-4: Use of Existing Highway Corridors.................................................................................3-15

Figure 3-5: Population Density in the Project Area ..........................................................................3-33

Figure 3-6: Employment Density in the Project Area .......................................................................3-34

Figure 3-7: Environmental Justice Populations in the Project Area .................................................3-36

Figure 3-8: Parklands, Wildlife Refuges, and Recreation Resources – Project Area South ...........3-45

Figure 3-9: Parklands, Wildlife Refuges, and Recreation Resources – Project Area North............3-46

Figure 3-10: Cultural Resources – Clayton and Fulton Counties, Georgia......................................3-53

Figure 3-11: Cultural Resources – Cobb County, Georgia...............................................................3-54

Figure 3-12: Cultural Resources – Bartow County, Georgia............................................................3-55

Figure 3-13: Cultural Resources – Floyd County, Georgia ..............................................................3-56

Figure 3-14: Cultural Resources – Gordon and Murray Counties, Georgia.....................................3-57

Figure 3-15: Cultural Resources – Whitfield and Catoosa Counties, Georgia.................................3-58

Figure 3-16: Cultural Resources – Hamilton County, Tennessee....................................................3-59

Figure 3-17: Water Resources – Clayton and Fulton Counties, Georgia.........................................3-67

Figure 3-18: Water Resources – Cobb County, Georgia .................................................................3-68

Figure 3-19: Water Resources – Bartow County, Georgia...............................................................3-69

Figure 3-20: Water Resources – Floyd County, Georgia .................................................................3-70

Figure 3-21: Water Resources – Gordon and Murray Counties, Georgia........................................3-71

Figure 3-22: Water Resources – Whitfield and Catoosa Counties, Georgia....................................3-72

Figure 3-23: Water Resources – Hamilton County, Tennessee.......................................................3-73

Figure 3-24: Watersheds ..................................................................................................................3-74

Figure 3-25: High Priority Waters in Georgia....................................................................................3-77

Figure 3-26: Ecoregions in Georgia..................................................................................................3-83

Figure 3-27: Critical Habitats ............................................................................................................3-91

APPENDICES

Tab

APPENDIX A – NOTICE OF INTENT .................................................................................................. A

APPENDIX B – CORRIDOR SCREENING PROCESS AND RESULTS............................................ B

APPENDIX C – RIDERSHIP FORECASTING REPORT..................................................................... C

APPENDIX D – FUNDING SOURCES................................................................................................. D

APPENDIX E – AGENCY COORDINATION AND PUBLIC OUTREACH ...........................................E
Table of Contents

Atlanta-Chattanooga HSGT Tier 1 DEIS xvi September 2016

APPENDIX F – DISTRIBUTION............................................................................................................F
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-1 September 2016

1.0 PURPOSE AND NEED FOR ACTION

1.1 Introduction

The Federal Railroad Administration (FRA), in cooperation with the Georgia Department of 

Transportation (GDOT) and the Tennessee Department of Transportation (TDOT), prepared this Tier 

1 Draft Environmental Impact Statement (DEIS) for the proposed Atlanta – Chattanooga High Speed 

Ground Transportation (HSGT) Project (Project). An Environmental Impact Statement (EIS) is 

required when a major federal action is likely to have a significant impact upon the quality of the 

human and/or natural environment. GDOT anticipates that if the Project were advanced, major 

federal actions would be required to support Project implementation. The Project is a proposed, new 

high-speed intercity passenger service connecting Atlanta, Georgia and Chattanooga, Tennessee.

HSGT is a self-guided intercity passenger ground transportation - by steel-wheel railroad or 

magnetic levitation (Maglev) - that is time competitive with air and/or auto for travel markets in the 

approximate range of 100 to 500 miles. The 'market' for HSGT is a city pair - two metropolitan areas 

and markets that, by their proximity and configuration, lend themselves to efficient service by ground 

transportation (FRA 1997). HSGT technology is a self-guided intercity passenger transportation 

mode that is time-competitive with air and auto for trips of 100 to 500 miles in length. It should be 

noted that the technology for the Project has not been selected; therefore, certain technologies such 

as steel-wheel trains or Maglev are still in consideration. FRA, GDOT, and TDOT have deferred 

evaluation and selection of the technology component of the Project to the Tier 2 National 

Environmental Policy Act (NEPA) phase.

GDOT defined a broad geographic Project Area for study that is contained, wholly or in part, in the 

following counties: Fulton, Cobb, Cherokee, Floyd, Bartow, Murray, Whitfield, Gordon, Chattooga, 

Catoosa, Clayton, Douglas, Paulding, Polk, and Walker counties of Georgia; and Hamilton County of 

Tennessee. Implementation of HSGT in the Project Area would have independent utility and it 

could form part of a larger transportation system. A project has independent utility “if it will result, 

upon completion, in the creation of new or substantially improved High-Speed Rail/Intercity 

Passenger Rail service, and will provide tangible and measurable benefits even if no additional 

investments in the same High-Speed Rail/Intercity Passenger Rail service are made” (FRA 2009).

The FRA is the federal lead agency for this Tier 1 DEIS and GDOT and TDOT are the joint lead 

state agencies. FRA, an operating administration within the United States Department of 

Transportation (USDOT), has partially funded the preparation of this Tier 1 DEIS under the 

Transportation Equity Act for the 21st Century (TEA-21) through fiscal year (FY) 2004 Appropriation.

Further, FRA has jurisdiction over the safety of railroad operations nationwide and is responsible for 

administering the High-speed Intercity Passenger Rail (HSIPR) Program. GDOT is leading the 

preparation of this Tier 1 DEIS, and TDOT is assisting in those efforts. GDOT is referred to in this 

Tier 1 DEIS as the “Project Sponsor.” FRA, GDOT, and TDOT have developed this Tier 1 DEIS 

pursuant to the National Environmental Policy Act of 1969 (NEPA) (42 United States Code [USC] § 

4332 et seq.), and implementing regulations (40 Code of Federal Regulations [CFR] Parts 1500-

1508); 49 USC § 303 (formerly Department of Transportation Act of 1966, Section 4(f)); National 

Historic Preservation Act (16 USC § 470); Clean Air Act as amended (42 USC §7401); the 

Endangered Species Act of 1973 (16 USC § 1531-1544); the Clean Water Act (33 USC § 1251-

1387); the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (42 

USC § 4601); Executive Order 12898 (Environmental Justice); Executive Order 11990 (Protection of 

Wetlands); Executive Order 13988 (Floodplain Management); FRA’s Procedures for Considering 

Environmental Impacts (64 Federal Register [FR] 28545), as well as the Safe, Accountable, Flexible, 

Efficient Transportation Equity Act: A Legacy for Users (Public Law 109-59; SAFETEA-LU); Moving 

Ahead for Progress in the 21st Century (MAP-21); and Fixing America's Surface Transportation Act 

(FAST Act)
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-2 September 2016

1.2 Tiering Process

The NEPA process for the Project began with the FRA’s publication of a Notice of Intent (NOI) in the 

Federal Register on August 22, 2007 (see Appendix A) to advise the public and other agencies that 

a Tier 1 DEIS would be prepared for the Project. 

The FRA, GDOT, and TDOT are using a tiered process, as provided for in 40 CFR 1508.28, to 

complete the NEPA environmental review of the Project. “Tiering” is a staged environmental review 

process applied to environmental reviews of complex projects covering large geographic areas. For 

the Atlanta – Chattanooga HSGT Project, Tier 1 will select a preferred corridor (generalized area of 

travel, such as ‘I-75’ or ‘I-75/Rome’); whereas Tier 2 will evaluate specific alignment routes within the 

preferred corridor selected in Tier 1.This Tier 1 DEIS states the purpose and needs for the Project; 

provides a broad assessment of the potential transportation, social, economic, and environmental 

impacts of the No Build Alternative and the alternative corridors for the Project; and presents the 

outcomes of public and agency coordination that were considered in the Tier 1 assessment and 

decision-making processes. After completing the Tier 1 DEIS process, including the public 

involvement period, FRA, GDOT, and TDOT may prepare a combined Tier 1 Final EIS 

(FEIS)/Record of Decision (ROD), which will identify a Preferred Corridor Alternative.

In this Tier 1 DEIS, exact locations of stations and potential maintenance and storage facilities sites 

were not determined. Likewise, a preferred technology for the Project will not be selected. Following 

FRA’s Tier 1 ROD, GDOT and TDOT will determine whether and how to move forward to implement 

a HSGT Project in the region. If the decision is made to move forward, and if sufficient funding is 

secured,4FRA, GDOT, and TDOT will prepare Tier 2 project-specific NEPA documents that examine 

potential impacts of the proposed action. FRA, in coordination with GDOT and TDOT, will determine 

the type of Tier 2 NEPA documents to be prepared at that time. The Tier 2 NEPA documents could 

include any of the following of three types based upon the proposed action:

 Categorical Exclusions (CEs) for actions that do not individually or cumulatively have a 

significant environmental effect.

 Environmental Assessments (EAs) for actions in which the significance of the environmental

impact is not clearly established. EAs can lead to the development of EIS documents or a

Finding of No Significant Impact (FONSI).

 Environmental Impact Statements (EISs) for projects where it is known that the action will have

significant environmental effect.

The Tier 2 studies will be detailed in nature, as appropriate to the action, and will continue the public

involvement effort that began in the Tier 1 process. The detailed environmental analyses in the Tier 

2 phase will assess the environmental impacts of each action and identify ways to avoid, minimize 

and mitigate impacts. FRA, GDOT, TDOT, and any invited cooperating federal agencies will use the 

Tier 2 NEPA phase to determine the exact location and magnitude of each action, such as types of 

structures, proposed station locations and configurations, storage and maintenance facility sites,

routing within existing right-of-way, bypasses, flyovers, tunnels, etc. As Tier 2 NEPA documents are 

completed, the permitting process (as appropriate) will be initiated and completed, and the 

construction process could proceed.

1.3 Project Background and Planning History

For the purpose of this Tier 1 DEIS, GDOT and TDOT defined a broad geographic Project Area for 

study that is contained, wholly or in part, in the following counties: Fulton, Cobb, Cherokee, Floyd, 

 

4

In September 2009, FRA awarded the Project approximately $13.8 million, authorized under the Safe, Accountable, Flexible, 

Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU). FRA has determined, however, that those funds may only 

be spent on a Maglev project. The award letter is in Appendix E
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-3 September 2016

Bartow, Murray, Whitfield, Gordon, Chattooga, Catoosa, Clayton, Douglas, Paulding, Polk, and 

Walker Counties of Georgia; and Hamilton County of Tennessee. The Project Area extends 

approximately 128 to 150 miles longitudinally, and up to 75 miles laterally. The Project Area is 

shown in Figure 1-1.

The concept of HSGT service between Atlanta, Georgia and Chattanooga, Tennessee has been 

studied for several years. Connections between Atlanta and Chattanooga were first studied by 

GDOT as a part of the 1997 Intercity Rail Plan. Between 1999 and 2003, the proposed project was 

considered for HSGT service as part of the FRA’s Maglev Deployment Program to demonstrate 

Maglev train technology in the United States. In a national competition, the FRA selected the Atlanta 

Regional Commission (ARC) to be one of seven entities in the United States to administer a study 

demonstrating the feasibility of Maglev technology. The ARC, in association with GDOT and the 

Georgia Regional Transportation Authority (GRTA), analyzed the proposed Project Area to explore 

the feasibility and opportunity for HSGT service. 

The Atlanta to Chattanooga Maglev Deployment Study and Project Description (ARC 2000) studied 

the southern end of the proposed Project Area between Hartsfield-Jackson Atlanta International 

Airport (HJAIA) and Town Center in north Cobb County. The study indicated that the proposed 

Project Area met all applicable FRA criteria established for Maglev technology. Although the Atlanta 

– Chattanooga Maglev Project was not selected for full funding for an EIS and Preliminary 

Engineering (PE), the segment from Town Center north to Chattanooga became eligible for funding 

for further study. 

In 2001, ARC received funding to conduct the Atlanta to Chattanooga Maglev Deployment Study 

Phase II (ARC 2002). Potential HSGT alignments and train technologies were studied in the

proposed Project Area between Town Center and the Chattanooga Metropolitan Airport (CMA). The 

potential HSGT alignments were assessed based on capital costs and financial performance relative 

to ridership projections and cost recovery based on the capabilities of the various technologies. 

Because HJAIA would generate significant ridership, the study concluded that the route must offer 

service to HJAIA.

The Atlanta to Chattanooga Maglev Deployment Study Phase II Addendum (ARC 2002) focused on 

the segment between HJAIA and Town Center. The addendum summarized the findings of the 

Atlanta to Chattanooga Maglev Deployment Study Phase II (ARC 2002), planning and environmental 

study, provided more detailed alignment maps and station plans, and provided operating and cost 

comparisons between alignments. The final chapter of the addendum explored a timeline for Maglev 

implementation. 

Following these studies, additional TEA-21 federal earmark funds and Section 115 Surface 

Transportation Program (STP) funds were appropriated to the Federal Highway Administration 

(FHWA) to support the development of a Tier 1 EIS for HSGT service in the Atlanta – Chattanooga 

Project Area. These funds were later transferred to FRA for the continued study of development of a 

HSGT system on the Atlanta-Chattanooga corridor. Under the current cooperative agreement, FRA 

agreed to re-obligate the remaining un-expended funds to complete the Tier 1 EIS, and therefore is 

the lead agency. 

The Long Range Transportation Plans (LRTPs) of Metropolitan Planning Organizations (MPOs) and 

the state DOTs in the Project Area incorporate references to the HSGT Project as follows:
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-4 September 2016

Figure 1-1: Project Area Map
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-5 September 2016

The Greater Dalton Metropolitan Planning Organization 2035 Long Range Transportation Plan 

(2010), includes six rail transportation strategies. One of these is to encourage the construction of 

the High Speed Maglev Train from Chattanooga to Atlanta. The plan states:

High-speed rail service from Chattanooga to Atlanta along I-75 through Whitfield 

County could greatly reduce the volume of traffic on I-75 and would greatly improve 

the integration and interconnections on a regional basis of a variety of modes of 

travel, particularly automobile and air travel. Other benefits of the High-speed Maglev

train would include the potential for new business developments and employment 

opportunities at a yet to be determined, proposed new Dalton Station site and along 

the corridors to serve passengers and local residents alike. This alternative mode of 

travel to and through the region would provide transportation choices for citizens of 

diverse income levels while improving the travel time, comfort and convenience for 

business travelers and tourists in the region.

Chattanooga Hamilton County North Georgia Long-Range Transportation Plan, Volume 1 2040 

LRTP Update (2014), prepared by the Chattanooga-Hamilton County Regional Planning Agency 

(CHCRPA), has a number of strategic planning concepts that support development of a more 

sustainable, multimodal, and cost-effective transportation program. These concepts include, by 

reference, the HSGT proposal.

Federal funding has been appropriated, though not yet authorized, for the 

continuation of project development for the Atlanta-Chattanooga-Nashville high 

speed rail corridor. It is anticipated that these funds will be released in the near 

future. Funding for implementation of the Project is expected to come from various 

sources including, but not limited to Federal Rail Administration, Federal Highway 

Administration, and Federal Transit Administration as well as state and local 

partners. Funding for this project will be included in a future RTP [Regional 

Transportation Plan] update given the status of the appropriations and likelihood the 

Project will move forward in the future.

The Rome-Floyd County Planning Department Long Range Transportation Plan 2040 (2012)

contains a rail section. The plan states that:

In 2009, GDOT carried out studies to construct a high speed passenger rail system 

between the Atlanta Hartsfield-Jackson Airport and the Chattanooga Airport. The 

current preferred route for that system would not include service in Floyd County. 

However, it would include a station in Cartersville that Floyd County residents would 

no doubt use in order to avoid the road congestion and parking issues associated 

with driving passenger vehicles to these airports.

Under the Needs section it states that:

The railway lines and facilities in the Floyd-Rome Urban Transportation Study 

(FRUTS) area are privately owned and operated. The local governments will 

continue to work with the railroad companies to assure efficient movement of freight 

while having minimal negative impact on the safe, efficient movement of motorize 

vehicles and pedestrians. The community encourages the state and federal 

governments to proceed with construction of intermodal projects that would provide 

passenger rail service to Atlanta, Chattanooga, and other destinations.

The purpose of the Project also has been identified as a potential rail initiative in TDOT’s 2035 Long 

Range Transportation Plan Amendment Modal Needs Final Report; which states that the HSGT 

Project will be monitored in coordination with the State of Georgia as it develops its concept for the 

Project (2007). 
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-6 September 2016

GDOT’s 2005-2035 Statewide Transportation Plan (2006) does not specifically reference this 

Project; however, passenger rail as a mode is an identified recommendation for its multimodal and 

intermodal initiatives.

TDOT prepared a statewide rail plan in 2003 that recommended intercity passenger service with 

neighboring states, including Georgia. A future connection to Nashville, Tennessee also was noted 

as a possibility. With intercity passenger service corridors in the planning stages to the east, west, 

and south of the Atlanta – Chattanooga Project Area, the Project could be part of an HSGT network 

serving the Southeast.

1.4 Purpose

The purpose of the Project is to enhance intercity mobility and economic growth throughout the 

Project Area between the metropolitan areas and the airports of Atlanta, Georgia, and Chattanooga, 

Tennessee, by providing faster and more reliable ground transportation service to the public as an 

alternative to highway, intercity bus, and air travel, in a manner that is safe and cost-effective, while 

avoiding, minimizing, and mitigating impacts on the human and natural environment. This purpose is 

supported by the LRTPs of MPOs in the Project Area and the state DOTs as discussed in Section 

1.3.

1.5 Needs

In this Tier 1 DEIS, FRA, GDOT, and TDOT are considering actions to address transportation needs 

stemming from increasing travel demand and forecast population and employment growth. 

Specifically, the needs for the Project include:

 Enhance Regional Transportation Mobility and Accessibility

 Population and Employment Growth

 Congested Transportation Corridor with Increasing Demand

 Limited Transportation Options

 Spur Economic Growth and Regional Vitality

 Provide Safe, Efficient, Reliable Transportation

 Enhance Airport Access and Intermodal Connections

 Improve Air Quality Nonattainment Areas and Minimize Environmental Impacts

1.5.1 Enhance Regional Transportation Mobility and Accessibility

Travel times between Chattanooga and Atlanta are:

 Air – 120 minutes (includes 60 minutes arrival prior to departure and airport gate to gate)

 Intercity bus – 125 to 185 minutes

 Automobile (on I-75) – 110 minutes (non-peak)

The Texas Transportation Institute reported in their 2011 Urban Mobility Report that the Atlanta 

region is the 13th most congested area in the United States with an average of 43 hours lost per 

person annually in travel (TTI 2011). As roadway congestion increases, intercity bus and automobile 

travel speeds on the roadway network will decrease, and travel times will increase. Because of these 

factors, the time it takes to travel between destinations, particularly by public transit that operates in 

mixed roadway traffic will become increasingly unreliable. Thus, there is a need for faster, more 

reliable transportation options in the Project Area.
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-7 September 2016

1.5.1.1 Population and Employment Growth

Between the years 2000 and 2012, the population of Georgia was the seventh fastest growing in the 

nation increasing from 8.1 million to 9.7 million, or 19 percent. During the same period, the 

Tennessee population grew 12 percent from 5.6 million to 6.4 million. As shown in Table 1-1, the 

populations of 11 of the 16 counties within the Project Area between the years 2000 and 2012 grew 

by 10 percent or more, including increases of 52 percent in Cherokee County and 74 percent in 

Paulding County. The metropolitan Atlanta population is forecasted to increase from 5.4 million 

people in 2010 to 8.3 million by the year 2040 (ARC 2010).

Table 1-1: Project Area Population Growth 1990 to 2012

County 1990 2000 2012

% 

Change 

1990-

2000

% 

Change 

2000-

2012

% 

Change 

1990-

2012

Bartow, GA 55,915 76,019 99,872 36% 31% 79%

Catoosa, GA 42,464 53,282 64,226 25% 21% 51%

Chattooga, GA 22,242 25,470 25,905 15% 2% 16%

Cherokee, GA 90,204 141,903 215,014 57% 52% 138%

Clayton, GA 182,052 236,517 262,066 30% 11% 44%

Cobb, GA 447,745 607,751 691,820 36% 14% 55%

Douglas, GA 71,120 92,174 132,124 30% 43% 86%

Floyd, GA 81,251 90,565 96,204 11% 6% 18%

Fulton, GA 648,776 816,006 929,535 26% 14% 43%

Gordon, GA 35,067 44,104 55,192 26% 25% 57%

Murray, GA 26,147 36,506 39,635 40% 9% 52%

Paulding, GA 41,611 81,678 141,846 96% 74% 241%

Polk, GA 33,815 38,127 41,350 13% 8% 22%

Walker, GA 58,340 61,053 68,463 5% 12% 17%

Whitfield, GA 72,462 83,525 102,152 15% 22% 41%

Hamilton. TN 211,000 307,896 337,023 46% 9% 60%

Total Project Area 2,120,211 2,792,576 3,302,427 32% 18% 56%

Georgia Total 6,478,216 8,186,453 9,714,569 26% 19% 50%

Tennessee Total 4,877,185 5,689,283 6,353,226 17% 12% 30%

Source: U.S. Census Bureau, Census 1990 and 2000, and American Community Survey 2012.

ARC forecasts regional employment will increase over 40 percent from 2.7 million jobs in 2010 to 4.5 

million in 2040 in metropolitan Atlanta, and the three leading sectors will be Health Care/Social 

Assistance adding some 276,000 jobs between 2005 and 2040, Professional and Technical services 

adding 257,000 jobs, and Real Estate adding 150,000 jobs. CHCRPA reports employment grew 

almost 18 percent between 1990 and 2012 and is forecasted to increase 40 percent from 218,612 in 

the year 2007 to 305,061 in 2035. As shown in Table 1-2, employment in the Project Area grew by 

over 40 percent from 1990 to 2012.
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-8 September 2016

Table 1-2: Project Area Employment Growth 1990 to 2012

County 1990 2000 2012 % Change 

1990-2000

% Change 

2000-2012

% Change 

1990-2012

Bartow, GA 13,875 22,874 42,991 64.9% 87.9% 209.8%

Catoosa, GA 20,146 27,154 29,467 34.8% 8.5% 46.3%

Chattooga, GA 9,868 10,722 9,487 8.7% -11.5% -3.9%

Cherokee, GA 48,237 75,316 105,797 56.1% 40.5% 119.3%

Clayton, GA 96,580 114,468 114,093 18.5% -0.3% 18.1%

Cobb, GA 253,096 329,136 353,496 30.0% 7.4% 39.7%

Douglas, GA 37,431 46,944 59,497 25.4% 26.7% 59.0%

Floyd, GA 38,308 40,403 39,587 5.5% -2.0% 3.3%

Fulton, GA 320,149 392,627 447,421 22.6% 14.0% 39.8%

Gordon, GA 17,439 22,451 23,399 28.7% 4.2% 34.2%

Murray, GA 13,247 17,802 15,499 34.4% -12.9% 17.0%

Paulding, GA 20,732 41,472 66,571 100.0% 60.5% 221.1%

Polk, GA 14,385 15,904 16,213 10.6% 1.9% 12.7%

Walker, GA 26,571 27,753 27,652 4.4% -0.4% 4.1%

Whitfield, GA 37,932 39,593 44,421 4.4% 12.2% 17.1%

Hamilton. TN 134,440 149,166 158,569 11.0% 6.3% 17.9%

Total Project Area 1,104,426 1,375,785 1,556,172 24.6% 13.1% 40.9%

Georgia Total 3,090,276 3,839,756 4,277,991 24.3% 11.4% 38.4%

Tennessee Total 2,250,842 2,651,638 2,815,491 17.8% 6.2% 25.1%

Source: U.S. Census Bureau, Census 1990 and 2000, and American Community Survey 2012.

1.5.1.2 Congested Transportation Corridor with Increasing Demand

The current and projected levels of congestion on the existing roadway network in 2010 and under 

the No-Build condition in 2040 are summarized in Table 1-3. The Levels of Service (LOS) and 

average daily traffic (ADT) are illustrated in Figures 1-2 and 1-3. Congestion is shown by LOS at 

representative points on the roadway network between Atlanta and Chattanooga based on a 

capacity analyses. LOS is a rating ranging from “A” through “F”. LOS A is the best, and represents 

free flow travel with no traffic congestion, while LOS F reflects conditions where traffic demand

exceeds capacity and extreme delays occur. ADT is the total traffic volume during a given time 

period, ranging from 2 to 364 consecutive days, divided by the number of days in that time period, 

and expressed in vehicles per day.

According to the analyses, with the exception of six roadway segments mostly located in rural areas, 

I-75 would operate at LOS D or worse in 2040 throughout the Project Area. Of the 18 segments 

analyzed along I-75, eight would experience LOS F. All eight segments are in metropolitan Atlanta. 

US 411, with the exception of one segment, would operate at D or worse in 2040 at all points 

studied. As LOS degrades and congestion becomes more widespread, travel times on the Project 

Area highway network will become longer. Base and future year LOS trends on US 41 are generally 

the same. The LOS varies where it is a LOS D or worse at the southern end of the Project Area until 

near I-20 where it is at a LOS A. The LOS begins to deteriorate further north of I-285 in Cobb County 

with a LOS E and begins to improve to LOS A in the Bartow County limits all the way to the 

Tennessee state line. Additional discussion regarding congestion on the highway network is found in 

Section 3.3.

The Georgia Interstate System Plan (GDOT 2004) reported that roadway travel demand along the 

majority of I-75, north of Atlanta, is projected to exceed capacity by 2030. Travel demand on US 41, 

US 411, and US 27, the other north-south routes between Atlanta and Chattanooga, also is 

expected to equal or exceed capacity within the next 30 years notwithstanding planned highway 

improvement projects. One proposed solution, the US 411 Connector, would provide a direct 

connection between I-75 and US 411 at its interchange with US 41 west of Cartersville. The 

Connector is intended to relieve congestion along the existing US 411/SR 20 to the I-75 corridor. 
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-9 September 2016

Given the projected increases in travel demand throughout the Project Area, additional solutions to 

existing and future travel demand are needed. 

Table 1-3: LOS on Major Routes in the Project Area (2010 and 2040)

Roadway Analysis Points LOS Roadway Analysis Points LOS

2010 2040 2010 2040

I-75 South of I-285 (Clayton County) E C

1 US 41 North of I-75 E E

I-75 North of I-285 E E

1 US 41 South of I-20 B B

I-75 North of US 41 D E US 41 South of 14th St. E C

I-75 /I-85 South of I-20 E F US 41 South of I-285 (Cobb County) B B

I-75 /I-85 South of 14th Street E F US 41 South of SR 280 C C

I-75 South of I-285 (Fulton County) E

1

F

1 US 41 North of Chastain Road F E

I-75 South of SR 280 E F US 41 North of SR 92 C C

I-75 South of I-575 E F US 41 South of SR 53 A A

I-75 North of Chastain Road E D

1 US 41 North of SR 136 C C

I-75 North of Wade Green Road D F US 41 North of Carbondale Rd. A

2 C2

I-75 North of Glade Road D E US 41 North of SR 201 A

2

A

2

I-75 South of SR 140 B C US 41 North of SR 146 A A

I-75 South of SR 53 C D US 411 East of SR 1 Loop C

2 D2

I-75 North of SR 136 E E US 411 East of Biddy Road B

2 D2

I-75 North of Carbondale Road C

2 C2 US 411 East of Alford Road C D

I-75 North of SR 201 D

2 C2 US 411 East of Harden Bridge Road C D

I-75 North of US 41 / SR 3 E E US 411 South of Falling Springs Road D E

I-75 North of SR 146 E E US 411 North of Salacoa Road D E

I-285 North of SR 280 E F US 411 North of SR 136 C D

I-285 North of Paces Ferry Road E F US 411 South of SR 2 A A

US 41 South of I-285 (Clayton County) D E US 76 West of US 411 A A

US 41 North of I-285 (Clayton County) E B

1Denotes sections of roadway network with proposed Managed Lanes system.

2

LOS represents roadway segments provided by MPOs that have a base year different than 2010 or a future year different than 

2040. The base year and future year for the Greater Dalton MPO is 2006 and 2035, respectively, and 2009 and 2040, respectively 

for the Rome Floyd-County MPO.

Sources: Transportation Demand Models for ARC, Greater Dalton MPO, Chattanooga-Hamilton County Regional Planning Agency, 

and Rome-Floyd County MPOs 2013 and TDOT 2014
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-10 September 2016

Figure 1-2: Roadway Level of Service (LOS) and Average Daily Traffic (ADT) – South

Sources: Transportation Demand Models for ARC, Greater Dalton MPO, Chattanooga-Hamilton County Regional Planning Agency, 

and Rome-Floyd County MPOs 2013 and TDOT 2014
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-11 September 2016

Figure 1-3: Roadway Level of Service (LOS) and Average Daily Traffic (ADT) – North

Sources: Transportation Demand Models for ARC, Greater Dalton MPO, Chattanooga-Hamilton County Regional Planning Agency, 

and Rome-Floyd County MPOs 2013 and TDOT 2014
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-12 September 2016

1.5.1.3 Limited Transportation Options

Intercity travel between Atlanta and Chattanooga is primarily by private automobile with only limited 

intercity bus service and no intercity rail service. Air shuttle flights are available between the cities, 

but this option is not always economical or competitive with auto travel time. Delta is the only airline 

that operates direct flights to Chattanooga from Atlanta. All other airlines require at least one stop 

before arriving to Chattanooga. Depending on when flights are reserved, fares can range from $200 

to over $600 (Delta 2014). In-flight travel time for direct flights is approximately 40 minutes. This time 

does not include travel to the airport or time necessary to process security, gate, and/or baggage 

checks. 

Private intra-city bus and transit services are available within the Atlanta region, Chattanooga and 

Rome, but do not serve the entire Project Area. For example, Groome Transportation provides a van 

airport shuttle service hourly, seven days a week for patrons traveling between HJAIA and 

Chattanooga (Groom Transportation 2014). It provides service between Chattanooga and Atlanta 

only in Dalton, Calhoun, and Marietta.

Greyhound and Megabus operate limited intercity bus service between Atlanta and Chattanooga. 

Greyhound offers six to eight daily departures, while Megabus provides approximately four daily 

departures (Greyhound and Megabus 2014). During off peak travel times, direct bus service travel 

time is approximately 21⁄2 hours between downtown Atlanta and downtown Chattanooga.

These findings demonstrate that Project Area transportation options are limited. In some cases, 

private automobile travel is the only transportation option. Thus, there is a need to increase 

transportation options in the Project Area. 

1.5.2 Enhance Airport Access and Intermodal Connections

HJAIA serves not only the Atlanta region, but also much of Georgia, for commercial air travel. HJAIA 

has been ranked as the world’s busiest airport since 1998. In 2013, it remained the world’s busiest 

passenger airport with over 94 million enplaning and deplaning passengers and over 900,000 take 

offs and landings as reported by Airports Council International (Airports Council International 2013).

As air travel at HJAIA increases and roadways become more congested and travel times more 

unreliable, there is a need for improved access to the airport. Currently, MARTA provides public 

transit access to HJAIA within its service area. The GRTA Xpress bus and Cobb Community Transit 

(CCT) services provide some connections to HJAIA from Cobb and Cherokee counties. Groome 

Transportation provides a van airport shuttle service hourly between HJAIA and Chattanooga with 

service stops in the cities of Dalton, Calhoun, and Marietta (GRTA and CCT 2014). However, 

Groome makes no other stops between Chattanooga and Atlanta (Groome 2014). Greyhound and 

Megabus bus provide service between Atlanta and Chattanooga, but not all parts of the Project Area

are served (Greyhound and Megabus 2014). Thus, there is a need to enhance transportation access 

to HJAIA in the Project Area.

CMA is a commercial airport that serves the Chattanooga area as well as south-central Tennessee, 

northeastern Alabama, and northwestern Georgia. Delta Connection provides nine flights per day 

between CMA and HJAIA, accounting for 28 percent of CMA’s total daily commercial aircraft traffic

(CMA 2014). The 2010 CMA plan, Master Plan Update Chattanooga Metropolitan Airport, identifies 

the need to increase the airport’s “catchment area” from which their passengers are drawn. The plan 

states that CMA captures only 55 percent of the region’s prospective enplanements. Airports in 

Nashville, Knoxville, Atlanta, Birmingham, and Huntsville capture the other 45 percent of the region's 

prospective enplanements.

The need for another airport serving the Atlanta region, encompassing the Project Area, has been 

under discussion for decades. As HJAIA approaches capacity in 2020, and roadways become more 

congested and travel times more unreliable, providing additional air service at CMA and improved
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Atlanta-Chattanooga HSGT Tier 1 DEIS 1-13 September 2016

ground access to CMA, could become an attractive option for air travelers originating in the Project 

Area. Thus, there is a need to enhance transportation access to CMA in the Project Area. 

In addition to airport access, connections to other transportation modes are needed. For example, a 

connection to MARTA would provide passengers access to a large number of Atlanta destinations 

within the MARTA service area. Likewise, intermodal connections to GRTA and CCT would provide 

access to destinations in those service areas. 

1.5.3 Spur Economic Growth and Vitality

Economic growth and development is critically important for the long-term vitality of the people and 

communities in the Project Area. Economic growth in terms of employment and tourism has been, 

and continues to be, forecast in Atlanta and to a lesser extent Chattanooga. For example, Atlanta 

and Chattanooga combined have approximately 45 million visitors annually. Atlanta has become one 

of the nation’s leading tourist destinations, both for Americans and international visitors, with 42

million visitors in 2012 (Atlanta Convention & Visitors Bureau 2014). Chattanooga also has grown as 

a tourist attraction and on average hosts approximately three million visitors annually (Beise 2014).

Employment and tourism will continue to be important aspects affecting growth of the entire project 

area. Between 1990 and 2012, employment increased by almost 40 percent in both Atlanta and in 

the portion of the Project Area within Georgia. In Chattanooga for the same period, the increase was 

25 percent. The recent growth in tourism within the Project Area is reported by the U.S. Travel 

Association in 2012 Travel Economic Impact on Georgia State, Counties and Regions, and The 

Economic Impact of Travel on Tennessee Counties 2012. On average, every $99,205 spent in 

Georgia and every $110,524 spent in Tennessee by domestic and international travelers generated 

one job in 2012. In 2012, domestic and international travelers’ spending in Georgia directly 

supported 241,800 travel industry jobs, an increase of 1.4 percent compared to 2011, and 146,200 

jobs in Tennessee, an increase of 1.6 percent. 

In the Atlanta metro region, 2012 expenditures by domestic and international travelers totaled $13.0 

billion or 54 percent of the statewide total. Fulton ranked number one in expenditures, Cobb ranked 

second, and Clayton ranked fourth. Hamilton, the only Tennessee county in the Project Area, ranks 

fourth among Tennessee counties. It had 2012 expenditures of $916.6 million or 16 percent of the 

statewide total, an increase of 4 percent over 2011. The impact of tourism in Georgia and 

Tennessee employment is summarized in Table 1-4. 

Table 1-4: Economic Impact of Tourism in Georgia and Tennessee 2011 compared to 2010

Measure 2011 experience 

in billions of 2011 dollars Change from 2010 (percent)

Georgia

Expenditures by domestic and 

international travelers 22.7 8.0

Earnings of travel industry employees 7.3 5.6

Tennessee

Expenditures by domestic and 

international travelers 25.1 8.6

Earnings of travel industry employees 9.2 4.8

Source: U.S. Travel Association 2011

Among Atlanta’s economic competitive advantages are its international airport, rail connections and 

interstate highway access. These transportation facilities attract and enable residents and visitors to 

contribute to the local economy. Yet, traffic congestion and delay compound the cost of doing 

business in the Atlanta and Chattanooga regions and reduce their competitive positions. While 

transportation is only one element in the formula for economic growth and vitality of an area, it is a 

substantial one. Outside Atlanta, where fewer transportation options are available, economic growth 

is metered by the ability of people to access jobs and destinations, both in and outside the Project 
Chapter 1 Purpose and Need for Action

Atlanta-Chattanooga HSGT Tier 1 DEIS 1-14 September 2016

Area. Thus, there is a need to address the transportation limitations that hinder economic growth 

and vitality.

1.5.4 Provide Safe, Efficient, Reliable Transportation

Projected growth in regional travel by truck, rail, auto, transit, and air over the next two decades 

underscores the need to provide safe transportation. Safety is a paramount consideration in 

expanding transportation options, with the focus on reducing or eliminating potential conflicts 

between people and vehicles. 

The National Highway Traffic Safety Administration notes that motor vehicle fatalities account for 

more than 90 percent of all transportation-related fatalities (2012). For the years 2010 through 2012, 

3,665 people died in motor vehicle crashes in Georgia, and 2,983 people died in motor vehicle 

crashes in Tennessee (National Highway Traffic Safety Administration 2013). In a highly-travelled 

highway corridor such as I-75 between Chattanooga and Atlanta, motor vehicle fatalities and 

accidents are a concern. Analysis of 2010-2013 crash data for I-75 within the Project Area shows an 

annual trend of over 4,300 crashes, 1,000 injuries, and over 15 fatalities (Georgia Highway Safety 

2014). The majority of these crashes, injuries and fatalities on I-75 occurred within the Atlanta 

metropolitan area. 

In stark contrast, recent FRA statistics indicate that passenger rail travel is one of the safest modes 

of transportation in terms of crashes and fatalities, particularly compared to highway travel. 

Nationally, passenger rail is one of the safest ways to travel, especially for intercity transport. Freight 

and passenger railroad safety in the U.S. has steadily improved over the past several decades and 

has remained one of the safest modes of intercity transport. In 2011, the number of U.S. fatalities on 

passenger trains was six passengers or under 1 percent of all transportation fatalities in comparison 

to autos, which were 32,367, or approximately 94 percent (FRA 2011). Thus, there is a need for a 

transportation service that is relatively safer than auto travel.

1.5.5 Improve Air Quality Nonattainment Areas and Minimize Environmental 

Impacts

Through the Clean Air Act (CAA) of 1970 and the CAA Amendments, the U.S. Environmental 

Protection Agency (USEPA) has issued National Ambient Air Quality Standards to protect the public 

health and welfare. Regions that do not meet the standards are designated as Nonattainment Areas. 

The counties within the Georgia portion of the proposed Project Area are designated as a NonAttainment Area for 8-hour ozone standard and the PM2.5 standard. The 1-hour ozone standard has 

been revoked for the 13-County Atlanta metro area (part of the 20-County area) as of June 15, 2005. 

Hamilton County, Tennessee is designated as a Non-Attainment Area for the 1997 PM2.5 standard.

One contributor to poor air quality in the Project Area is the dominance of road-based travel and the 

exhaust emissions that result. Thus, there is a need to consider means to improve air quality and not 

exacerbate air quality problems when implementing a new transportation project. There also is a 

need to protect the natural and built environment in the proposed Project Area.

1.6 Project Goals and Objectives 

The goals and objectives for the Project support the purpose and need and were identified through 

Scoping (see Section 2.1), including stakeholder and public outreach activities. These goals and 

objectives relate to the avoidance, minimization, and mitigation of environmental impacts and

support of economic growth in the Project Area that is consistent with local, regional, statewide and 

national land use and transportation planning. The following goals define the purpose of the Project

and are further defined with individual objectives:

 Improve regional mobility;
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Atlanta-Chattanooga HSGT Tier 1 DEIS 1-15 September 2016

 Support and ensure consistency with national, state, and local transportation planning 

initiatives;

 Avoid or minimize environmental impacts; and

 Promote financial and economic growth.

1.6.1 Improve Regional Mobility

Greater regional passenger mobility enhancement and options are needed to address current and 

future travel demand and population growth in the Atlanta – Chattanooga Project Area. The following 

objectives outline this goal:

 Enhance Project Area and intercity mobility;

 Provide an alternative mode to auto travel;

 Provide a reduction in travel time within and between the major metropolitan areas of Atlanta 

and Chattanooga;

 Provide intercity travel capacity to supplement over-used interstate highways;

 Meet future intercity travel demand that existing transportation systems cannot accommodate, 

and increase capacity for intercity mobility;

 Maximize intermodal connections with local transit, major airports, and highways; and

 Support population and employment growth by providing access to HSGT service.

1.6.2 Support and Ensure Consistency with National, State, and Local 

Transportation Planning Initiatives

An efficient and effective transportation system is one that is coordinated with land use and 

development decisions. Integrating land use decisions with transportation infrastructure investment 

is the best approach to address the proposed Project Area’s challenges, and promote healthy, 

sustainable economic development and desirable communities. 

Effective transportation links among important Project Area activity centers and major business 

development areas provide for worker access to jobs, business access to markets, and resident 

access to services. In addition, passenger stations have the potential to influence and support 

denser development patterns. This may occur directly through joint development opportunities and 

indirectly by enhancing land values around proposed station locations. 

On a larger scale, GDOT and TDOT have a goal to implement and support federal transportation 

policies encouraging public transportation investments that increase national productivity and 

domestic and international competition, as well as improve social and environmental conditions. 

These policies encourage investments that:

 Reduce energy consumption;

 Link all modes of transportation; and

 Improve public transportation systems and services.

1.6.2.1 National Transportation Planning

Several USDOT sponsored high-speed rail corridors in the planning stages would utilize Atlanta as a 

key hub, including: a westward corridor to Birmingham, AL; a northeastward corridor to Greenville 

and Charlotte, NC; and a southward corridor to Macon, GA and Jacksonville, FL (see Figure 1-4 for 

the USDOT High Speed Intercity Passenger Rail Program Map). Network linkages are important to 

the planning and success of the regional HSGT system. The Tennessee Rail System Plan (TDOT 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 1-16 September 2016

2003) notes that the existing passenger rail network in the eastern United States bypasses 

Tennessee. Likewise, a review of federally-designated high-speed rail (HSR) corridors shows little 

connectivity between the system in the Southeast region and the designated system in the Midwest. 

As noted in the Georgia Rail Plan, the Atlanta-Chattanooga-Louisville corridor is under 

consideration, and that corridor could serve as an important link in connecting the systems in the 

Southeast and Midwest. Thus, there is a need to provide this critical link in the future regional HSGT 

network (2009).

Figure 1-4: USDOT High Speed Intercity Passenger Rail Program

Source: FRA. 2009. Vision for High Speed Rail in America

1.6.2.2 State and Local Planning

As noted in Section 1.3, Project Area MPOs have discussed this Project in their long range 

transportation plans. At the state level, GDOT first studied the proposed Project Area as part of an

Intercity Rail Plan (1997). HSGT and destinations along the proposed Project Area also have been 

noted in GDOT’s 2005-2035 Statewide Transportation Plan, GDOT’s FY 2015-2018 State 

Transportation Improvement Program (STIP) (2014), and subsequent State Rail Plan (2009), and 

TDOT’s Tennessee Rail System Plan (2003). 

GDOT’s 2005-2035 Statewide Transportation Plan did not include specific projects. Instead, it 

generally assessed the transportation system and identified goals for future transportation 

infrastructure development. Among others, these goals included the following:

 Support the economic viability of Georgia and the U.S. by enabling global competiveness, 

productivity, and efficiency;
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Atlanta-Chattanooga HSGT Tier 1 DEIS 1-17 September 2016

 Increase the safety of transportation infrastructure for motorized and non-motorized users;

 Increase the mobility of people and freight

 Protect and enhance the environment, promote energy conservation, improve the quality of life, 

and promote consistency between transportation improvements and state and local planned 

growth and economic development patterns; and

 Enhance the integration and connectivity of the transportation system, across and between 

modes throughout Georgia, for people and freight.

Georgia’s State Rail Plan (GDOT 2009) was prepared in accordance with federal requirements 

established in the Passenger Rail Investment and Improvement Act (PRIIA) of 2008. The plan notes 

the vision for rail transportation in Georgia and includes the following tenets:

 Serve Georgians well for both passenger and freight services;

 Provide a preferred choice for intra-state travelers and shippers;

 Provide seamless and energy-efficient intermodal connections; and 

 Provide a system that supports economic growth and development.

The plan includes a discussion of past studies conducted by GDOT for passenger rail, including 

Amtrak, intercity passenger services, and HSR. A policy statement is included in the plan that 

commits GDOT to:

Take an active leadership role in the incremental development and implementation 

of high-speed passenger rail service with efforts to realize 200 mph service in the 

future (GDOT 2009).

It also notes that three federally-designated HSR corridors are present in Georgia – the Gulf Coast 

Corridor and the central and Atlantic branches of the Southeast High Speed Rail Corridor. The fact 

that two of these corridors connect to Atlanta, making it a hub for HSGT in the southeast, 

demonstrates the goal that the decisions arising from this NEPA process would be consistent with 

GDOT’s plan.

TDOT’s Tennessee Rail System Plan (2003) notes that based on projected ridership and costs, the 

Louisville-Nashville-Chattanooga corridor would be the best for initial passenger service in 

Tennessee. The first step in the plan is to extend service from Louisville to Nashville, then to 

Chattanooga and Atlanta. Thus, the decisions arising from this NEPA process would demonstrate 

consistency with TDOT’s plan.

1.6.3 Avoid or Minimize Environmental Impacts

Through the NEPA and design processes, GDOT and TDOT will strive to avoid or minimize 

environmental impacts, and provide mitigation for unavoidable impacts. Critical environmental 

objectives include:

 Maximize the use of existing transportation corridors and rights-of-way to the extent practicable;

 Avoid and minimize adverse impacts to historic and archaeological properties, cemeteries, 

parks, and wildlife refuges;

 Avoid, minimize and mitigate impacts to wetlands, lakes, streams, floodplains and critical 

threatened and endangered species habitat; and

 Improve regional air quality of the proposed Project Area and help reduce vehicle emissions 

exacerbating regional Nonattainment Areas.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 1-18 September 2016

1.6.4 Promote Financial and Economic Growth

From a financial perspective, an action arising from this NEPA process should be a cost-effective 

transportation investment in terms of providing a reasonable balance between the estimated cost of 

the action and its ability to meet the purpose and need. Critical financial objectives include:

 Provide a cost-effective transportation investment and minimize capital costs where possible; 

and

 Develop a practical and economically viable transportation system.

GDOT and TDOT have a goal to enhance transportation options that support economic growth, 

enhance the tourism industry and help bolster economic development throughout the proposed 

Project Area. Critical economic objectives include:

 Improve population and employment access to improved transit service;

 Enhance mobility and attractiveness of Project Area to encourage job growth and tax base 

increase;

 Support population and employment growth through access to HSGT service; and

 Enhance transportation options that support economic growth, enhance the tourism industry

and help bolster economic development.
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-1 September 2016

2.0 ALTERNATIVES CONSIDERED

A wide range of high speed ground transportation (HSGT) mode technologies and alignments have

been examined throughout the history of this Project. This chapter describes the process by which 

technologies and a range of reasonable corridor alternatives, including the No-Build Alternative,

were considered. The evaluation processes that were used comply with guidelines of the NEPA; the 

Safe, Accountable, Flexible, and Efficient Transportation Equity Act—A Legacy for Users

(SAFETEA-LU); the Moving Ahead for Progress in the 21st Century Act (MAP-21), and Fixing 

America's Surface Transportation Act (FAST Act). The alternatives evaluated in this Tier 1 DEIS are 

also described.

2.1 Scoping 

Scoping for the proposed project was an important part of the initial alternatives definition. Scoping is 

the first step in the environmental review process under NEPA. At this stage, agencies, 

organizations, and the public help to determine the scope of issues to be addressed in the Tier 1 

DEIS, and identify the significant issues related to the proposed action. The input received during 

scoping helps to identify the appropriate alternatives and the depth and breadth of environmental 

analysis to be completed. The formal public scoping process for the Project began with FRA’s

publication of the Notice of Intent (NOI) to prepare a Tier 1 DEIS, in the Federal Register on August 

22, 2007, (see Appendix A) and ended October 4, 2007. During the scoping process, the public, 

stakeholders, and government agencies provided input on:

 The purpose and need for the proposed Project;

 Potential mode technologies;

 Potential corridors and station or stop locations;

 Potential environmental issues;

 Methodology for selecting the corridors for further study; and

 Opportunities for public involvement.

The public scoping process for the Project was conducted in accordance with 23 CFR 771.123 and 

40 CFR 1501.7. 5 Chapter 7 provides further information pertaining to agency, stakeholder, and 

public coordination efforts.

2.1.1 High Speed Ground Transportation Train Technologies

Although the Tier 1 Record of Decision for this project will not include a decision on technology, the 

scoping process identified several potential HSGT train technologies that could serve the Project 

Area. HSGT is a mode of transportation that can travel at greater speeds than traditional rail 

technology and can provide improved passenger mobility and reduce travel times in the Project 

Area. For this proposed project, HSGT is defined as trains that can operate at speeds fast enough to 

provide trip times that are competitive with air, intercity bus, and highway travel. Train technologies

that are competitive with air, intercity bus, and highway travel for trips of 100 to 500 miles would 

meet the Project’s purpose and need. 

Train technologies considered for this Project included: diesel multiple unit, diesel steel-wheel, diesel 

–electric steel-wheel, electric steel-wheel, and magnetic levitation (Maglev).

The following provides summary descriptions of the train technologies considered for this project:

 Diesel Multiple Unit (DMU) – These diesel-powered vehicles are steel wheel on steel rail trains

providing regional, intra-city passenger service mainly in Europe and formerly in the United 

 

5 When the Project began, FHWA was a co-Lead Agency for the project. As such, FHWA regulations as well as FRA regulations 

were referenced.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 2-2 September 2016

States (see Figure 2-1). The service routes of these vehicles are typically 30 to 35 miles long. 

Trains can achieve a maximum speed of approximately 90 miles per hour (mph), but average 35 

mph due to stopping patterns that requires closely spaced stations to support the intra-city, 

commuter service this technology typically provides. This technology is suited for regional, intracity travel from outer-ring suburbs to the urban core; however, it is not fit for high-speed 

interstate and intercity travel due to its slower speeds. 

Figure 2-1: Diesel Multiple Unit

Source: Alstom Transport, http://www.alstom.com/products-services/product-catalogue/railsystems/trains/products/coradia-lint-regional-train/

 Diesel Steel-Wheel – These diesel-powered vehicles are steel wheel on steel rail trains typically 

used for commuter and intercity trips ranging from 30 miles to 75 miles. Trains can achieve 

speeds ranging from 79 to 110 mph. In typical operations, passenger trains utilizing this 

technology share track with freight rail traffic. Stations are closely spaced (7 to 10 miles apart)

and trains tend to average 59 to 69 mph or less due to station stopping patterns. This train 

technology is in operation in several locations around the United States as a regional 

transportation alternative to the automobile or bus service. It is best suited for regional, intra-city 

travel from outer-ring suburbs to an urban core, and is less appropriate for high-speed interstate 

and intercity travel due to its slower operating speeds. Figure 2-2 provides an example of dieselpowered steel wheel train in Chicago, Illinois.
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-3 September 2016

Figure 2-2: Diesel Steel-Wheel Metra Commuter Rail, Chicago, Illinois

Source: Wikimedia Commons 2014

 Diesel-Electric Steel-Wheel – These electric- and/or diesel-powered vehicles are steel wheel 

on steel rail trains utilized for long distances. Electric-powered vehicles are in use in the 

Northeast Corridor of the United States between Boston and Washington, DC with service 

provided by Amtrak. This technology often operates on exclusive track and does not have to 

compete with freight rail traffic. Trains can achieve speeds ranging up to 150 mph, but because

stations are typically spaced about 30 to 40 miles apart, trains tend to average about 90 mph. 

Figure 2-3 shows a typical Amtrak train.

Figure 2-3: Diesel – Electric Steel-Wheel Amtrak Train set, Northeast Corridor 

Source: Wikimedia Commons 2014

 Electric Steel-Wheel – This train technology utilizes electric-powered vehicles that receive 

energy from overhead wires (see Figure 2-4). The vehicles are steel wheel on steel rail and

usually operate on a grade-separated right-of-way (ROW) to eliminate potential points of conflict 

with pedestrians, motor vehicles, and other rail lines. Per 49 CFR 213.347, there shall be no atgrade (level) highway crossings, public or private, or rail-to-rail crossings at-grade on Class 8 

and 9 tracks.

6

FRA limits the maximum allowable operating speed for trains on class 8 track to 

 

6

49 CFR Part 213. https://www.gpo.gov/fdsys/pkg/CFR-2011-title49-vol4/pdf/CFR-2011-title49-vol4-part213.pdf
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-4 September 2016

160 mph and 220 mph for class 9 tracks.7FRA limits class 7 track to 125 mph operations and 

there can be at-grade crossings, but when activated a warning/barrier system must be in place to 

provide physical separation between roads and tracks. In addition, passenger rail operating at 

speeds above 125 mph do not share track with freight service due to safety concerns and 

operational efficiently. Therefore, higher speeds and reliable passenger schedules can be met. 

Vehicle speeds of up to 220 mph are possible. With the exception of portions of the Northeast 

Corridor where electrified Amtrak Acela trains operate at speeds up to approximately 150 mph; 

this technology is not in use in the United States. However, Europe and Asia use it quite 

extensively. This technology is well suited for intercity travel, and previous studies (Intercity Rail 

Plan, GDOT 1997 and Scoping Summary Report, GDOT 2008) conducted in the Atlanta to 

Chattanooga corridor documented the ability of this technology to provide a travel time 

competitive with automobile travel within the corridor (See Section 1.2). 

Figure 2-4: Electric Steel-wheel Train, Alta Velocidad Espanola (AVE), Toledo, Spain

Source: AECOM 2014

 Magnetic Levitation (Maglev) – Maglev utilizes magnetic forces to lift and propel the train along 

a guideway. Maglev allows the vehicles to hover or float a small distance above the guideway, 

thereby eliminating friction and rolling resistance. The power is supplied to the magnets through 

the guideway. Maglev vehicles are capable of speeds of over 300 mph. Maglev requires its own 

guideway and it can be at-grade, elevated or placed in tunnels. However, Maglev guideways are 

incompatible with at-grade roadway crossings. Maglev would not rely upon at-grade roadway 

crossings and, therefore, avoids that particular safety concern. Higher train speeds is an added 

benefit of Maglev being completely grade separated. Design characteristics of the guideway 

could affect average speeds, station spacing, and the number of stations. While there are 

currently no Maglev systems that provide intercity HSGT service, the German Transrapid system 

is in commercial operation in China on a track over 20 miles long between downtown Shanghai 

and the Pudong Airport (see Figure 2-5). Maglev is also in operation in central Japan and 

another system is under construction in Beijing. This technology is appropriate for intercity travel, 

and previous studies (GDOT 1997 and GDOT 2008) conducted in the Atlanta to Chattanooga 

corridor documented the ability of this high-speed technology to provide a travel time competitive 

with automobile travel within the corridor (See Section 1.3). 

 

7

FRA. 2014. https://www.fra.dot.gov/Elib/Document/3020
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Atlanta-Chattanooga HSGT Tier 1 DEIS 2-5 September 2016

Figure 2-5: The Shanghai Transrapid Maglev Train

Source: Wikimedia Commons 2014

Table 2-1 provides estimated travel times for each of the train technologies described above. For 

comparison, the table also includes auto, air and intercity bus travel times. All travel times presented 

are end to end (HJAIA to Chattanooga) estimations and based on average speeds of each 

technology.

Table 2-1: Travel Times by Train Technology and Transportation Mode

Transportation Mode Approximate Travel 

Time1(minutes)

Train Technology

DMU 113-129

Diesel Steel-Wheel 76-87

Diesel-Electric Steel-Wheel 59-68

Electric Steel-Wheel 44-50

Maglev 36-41

Existing Travel Modes

Automobile 110

Intercity Bus 125-185

Air2120

1Estimated travel time measured during optimal travel conditions.

2

Includes 60 minutes arrival prior to departure and airport gate to gate.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 2-6 September 2016

As indicated in the table above, even under optimal conditions, DMU travel times are at best 

comparable to those for air8and automobile, and may be worse. DMU technology generally 

performs better than intercity bus under most travel conditions, although in some instances, intercity 

bus may be marginally faster. Overall, however, unlike the other train technologies, DMU travel 

times do not offer much or any improvement over travel times for existing modes. Therefore, DMU 

was eliminated from further consideration since it would not meet the project’s purpose and need; 

specifically, the need to “enhance regional transportation mobility and accessibility” to provide HSGT 

service that is time-competitive with air-, intercity bus-, and auto-travel along the corridor.

An HSGT train technology will not be selected until the Tier 2 NEPA phase in which a more detailed 

level of environmental analysis and engineering will occur. The feasibility of diesel steel-wheel, 

diesel-electric, electric, and Maglev train technologies, will be considered in more detail and a 

technology selection will be made during the Tier 2 NEPA process.

2.1.2 HSGT Segments and Corridors

In preparation for the scoping process, the Project Team developed a series of potential HSGT 

“segments” that could be combined in various configurations to connect HJAIA, Chattanooga 

Metropolitan Airport (CMA), and the downtowns of Atlanta and Chattanooga. Within this context, 

“segments” are not to be construed as minimum operating segments, initial operating segments, or 

any form of train service operating independently of a corridor extending the entire length of HJAIA 

to downtown Chattanooga. These segments were generated from a review of previous studies that 

analyzed transportation improvements within the I-75 corridor between Atlanta and Chattanooga. 

The following studies were reviewed and used to develop the HSGT segments:

 Georgia Intercity Rail Plan Final Report (March 1997);

 Atlanta to Chattanooga Maglev Deployment Study Environmental Assessment (February 2000);

 Concept Design Report for the Multimodal Passenger Terminal (February 2002);

 Atlanta to Chattanooga Maglev Deployment Study, Phase II (March 2002);

 High Speed Trains Nashville – Chattanooga – Atlanta (November 2003);

 Chattanooga Hamilton County/North Georgia Comprehensive Transportation Plan 2030, Long 

Range Transportation Plan (LRTP) (June 2005); and

 ARC Envision 6/Mobility 2030 Regional Transportation Plan (RTP) (May 2006).

Each segment represents a potential connection that could be made between key destinations in 

Georgia and Tennessee. For instance, a segment can connect Atlanta to Cartersville (two logical 

destinations), and the next segment can connect Cartersville to Rome or Cartersville to DaltonChatsworth, and so on. These segments were reviewed, analyzed, and developed into full-length 

corridors during the scoping process using input from the public and participating agencies as per 

SAFETEA-LU, FRA’s Procedures For Considering Environmental Impacts (64 FR 28545), and the 

Council Environmental Quality (CEQ) Regulations for Implementing NEPA (40 CFR Parts 1500-

1508). The individual segments identified during the scoping process are listed below, generally from 

south to north, and illustrated on Figure 2-6. 

 I-75 Segment(s): The Interstate 75 (I-75) segments generally follow the I-75 ROW from the area 

to the east of HJAIA, known as the “Southern Crescent” located on the east side of HJAIA, just

east of I-759, to the Tennessee border;

 

8

The calculation for travel time for air travel includes 60 minutes arrival prior to departure and airport gate to gate.

9

The “Southern Crescent” area is located on the east side of HJAIA, just east of I-75. The location is proposed as a regional transit 

terminal that could include various transit modes such as Metropolitan Atlanta Rapid Transit Authority (MARTA) rail and bus, 

regional commuter rail, and other transit services. Although no specific plan has been adopted, the concept for access to HJAIA 

from the Southern Crescent would be the construction of an Automatic People Mover (APM) using the median of the new 

international terminal roadway. 
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-7 September 2016

 NS Segment: A connection within metropolitan Atlanta, which follows I-75 to an existing Norfolk 

Southern (NS) railroad ROW and a portion of I-285 to just south of the I-75/I-285 junction rather 

than continuing on I-75;

 HJAIA to I-285 Segment: A connection within metropolitan Atlanta from the Main Terminal of 

HJAIA along Camp Creek Parkway to Interstate 285 (I-285);

 I-285 Bypass Segment(s): Segments using I-285 to bypass I-75 within metropolitan Atlanta;

 Rome Segment(s): Segments that provide options to connect to the city of Rome and back to I75, bypassing the dense I-75 Corridor in the southwest section of the Project Area by traveling 

through Rockmart and Douglas County. It follows parts of Camp Creek Parkway and utility 

corridors in rural areas;

 Rome to I-75 Segment: Provides a connection directly to Rome from I-75 near Cartersville;

 Western Suburb Segment: A connection in the southern half of the Project Area, which travels 

from a point just north of Douglasville to Cartersville;

 Eastern Segment: A connection in the northern half of the Project Area that follows an existing 

rail corridor. It leaves the I-75 corridor north of Cartersville and generally follows the Chessie 

Seaboard Express (CSX) railroad corridor to the CMA vicinity in Chattanooga, TN; and

 Downtown Chattanooga Segment: A connection from CMA to downtown Chattanooga 

following an existing CSX rail line ROW
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-8 September 2016

Figure 2-6: Segments 
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-9 September 2016

2.1.2.1 Identification of Corridors and Stations

The Project Team combined the individual segments listed above to form 15 corridors extending 

from HJAIA to downtown Chattanooga. Segments were assembled based on logical connections 

between key destinations, paying special attention to minimizing the corridor length, utilizing 

available transportation ROW, and fulfilling the needs of the populations to reach key destinations 

within the Project Area. Table 2-2 lists the full-length corridors that were generated from the scoping 

process. Figure 2-7 through Figure 2-15 depict the corridors. Note that more than one corridor is 

shown on some maps.

Potential station locations were identified along each corridor alternative in areas that would serve 

clusters of higher population and employment densities and that would be accessible by other 

transportation modes such as airports, city centers, major interstate highways, or major points of 

interest. Potential station location choices also were based upon the results of scoping and 

coordination with local city and county officials. The potential station locations, configurations, and 

layouts will be refined during the Tier 2 NEPA phase. Identifying potential station locations during 

this Tier 1 stage enables initial analysis of various impacts. Table 2-2 lists the potential station 

locations for each corridor. Subsequent Tier 2 analysis will utilize FRA’s Station Area Planning for 

High-Speed and Intercity Passenger Rail (2011).

Table 2-2: HSGT Project Corridors and Potential Station Locations Considered

Corridor

Total 

Length 

(miles)

Number 

of 

Stations

Potential Station Locations

I-75 Terminal I-285 – HJAIA Terminal to I-285 Bypass 

via Camp Creek Parkway, to I-75 north to CMA and 

downtown Chattanooga

129 8

 HJAIA Terminal

 Boulder Park

 Cumberland/Galleria

 Town Center

 Cartersville

 Dalton

 CMA

 Downtown 

Chattanooga

I-75 Southern Crescent NS – Southern Crescent 

through downtown Atlanta along I-75, west on NS to I285 Bypass, reconnect to I-75 north to CMA and 

downtown Chattanooga

131 8

 Southern Crescent

 Downtown Atlanta

 Cumberland/Galleria

 Town Center

 Cartersville

 Dalton

 CMA

 Downtown 

Chattanooga

I-75 Southern Crescent – Southern Crescent through 

downtown Atlanta along I-75 north to CMA and 

downtown Chattanooga

128 8

 Southern Crescent

 Downtown Atlanta

 Cumberland/Galleria

 Town Center

 Cartersville

 Dalton

 CMA

 Downtown 

Chattanooga

East Terminal I-285 – HJAIA Terminal to I-285 

Bypass via Camp Creek Parkway to I-75, traverse the 

Eastern Segment up to CMA and downtown 

Chattanooga

144 8

 HJAIA Terminal

 Boulder Park

 Cumberland/Galleria

 Town Center

 Cartersville

 Dalton

 CMA

 Downtown 

Chattanooga

East Southern Crescent NS – Southern Crescent 

through downtown Atlanta along I-75, west on NS to 

the I-285 Bypass, reconnect to the I-75, traverse the 

Eastern Segment, north to CMA and downtown 

Chattanooga

141 8

 Southern Crescent

 Downtown Atlanta

 Cumberland/Galleria

 Town Center

 Cartersville

 DaltonChatsworth

 CMA

 Downtown 

Chattanooga

East Southern Crescent – Southern Crescent 

through downtown Atlanta along I-75, traverse the 

Eastern Segment up to CMA and downtown 

Chattanooga

139 8

 Southern Crescent

 Downtown Atlanta

 Cumberland/Galleria

 Town Center

 Cartersville

 DaltonChatsworth

 CMA

 Downtown 

Chattanooga

I-75/West – HJAIA Terminal to I-285 Bypass, traverse 

the Rome Segment to the Western Suburb Segment, 

connect to I-75 north to CMA and downtown 

Chattanooga

141 6

 HJAIA Terminal

 Douglas County

 Cartersville

 Dalton 

 CMA

 Downtown 

Chattanooga
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-10 September 2016

Corridor

Total 

Length 

(miles)

Number 

of 

Stations

Potential Station Locations

I-75/Rome Split – HJAIA Terminal to I-285 Bypass, 

traverse the Rome Segment to the Western Suburb 

Segment, west on the Rome to I-75 Segment, traverse 

back east on Rome Segment to I-75 and north to CMA 

and downtown Chattanooga

162 7

 HJAIA Terminal

 Douglas County

 Cartersville

 Rome

 Dalton 

 CMA

 Downtown 

Chattanooga

I-75/Rome Terminal I-285 – HJAIA Terminal to I-285 

Bypass via Camp Creek Parkway to I-75, west on the 

Rome to I-75 Segment, traverse back east on Rome 

Segment to I-75, north to CMA and downtown 

Chattanooga

150 9

 HJAIA Terminal

 Boulder Park

 Cumberland/Galleria

 Town Center

 Cartersville

 Rome 

 Dalton 

 CMA

 Downtown 

Chattanooga

I-75/Rome Southern Crescent NS – Southern 

Crescent through downtown Atlanta along I-75, west 

on NS to the I-285 Bypass, reconnect to I-75, west on 

the Rome to I-75 Segment, traverse back east on 

Rome Segment to I-75, north to CMA and downtown 

Chattanooga

152 9

 Southern Crescent

 Downtown Atlanta

 Cumberland/Galleria

 Town Center

 Cartersville

 Rome 

 Dalton 

 CMA

 Downtown 

Chattanooga

Table 2-2: HSGT Project Corridors and Potential Station Locations Considered (continued)

Corridor

Total 

Length 

(miles)

Number 

of 

Stations

Stations

I-75/Rome Southern Crescent – Southern Crescent 

through downtown Atlanta along I-75, west on the 

Rome connector, traverse back east to reconnect to I75 up to CMA and downtown Chattanooga

150 9

 Southern Crescent

 Downtown Atlanta

 Cumberland/Galleria

 Town Center

 Cartersville

 Rome 

 Dalton 

 CMA

 Downtown 

Chattanooga

West – HJAIA Terminal to I-285 Bypass, traverse the 

Rome segment to I-75 up to CMA and downtown 

Chattanooga

148 7

 HJAIA Terminal

 Douglas County

 Rockmart

 Rome

 Dalton

 CMA

 Downtown 

Chattanooga

West Connector – HJAIA Terminal to I-285 Bypass, 

traverse the Rome segment, east on the Rome 

connector, connect to I-75 up to CMA and downtown 

Chattanooga

174 8

 HJAIA Terminal

 Douglas County

 Rockmart

 Rome

 Cartersville

 Dalton

 CMA

 Downtown 

Chattanooga

West/East – HJAIA Terminal to I-285 Bypass, traverse 

the Rome segment to the Western Suburb segment, 

connect to the Eastern segment up to CMA and 

downtown Chattanooga

151 6

 HJAIA Terminal

 Douglas County

 Cartersville

 Dalton-Chatsworth

 CMA

 Downtown 

Chattanooga

West/East Connector – HJAIA Terminal to I-285 

Bypass, traverse the Rome segment, east on the 

Rome connector, connect to the Eastern segment up 

to CMA and downtown Chattanooga

181 8

 HJAIA Terminal

 Douglas County

 Rockmart

 Rome

 Cartersville

 DaltonChatsworth

 CMA

 Downtown 

Chattanooga
Chapter 2.0 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-11 September 2016

Figure 2-7: I-75 Terminal I-285, I-75 Southern Crescent NS, I-75 Southern Crescent Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-12 September 2016

Figure 2-8: East Terminal I-285, East Southern Crescent NS, East Southern Crescent Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-13 September 2016

Figure 2-9: I-75/West Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-14 September 2016

Figure 2-10: I-75/Rome Split Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-15 September 2016

Figure 2-11: I-75/Rome Terminal I-285, I-75/Rome Southern Crescent NS, I-75/Rome Southern 

Crescent Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-16 September 2016

Figure 2-12: West Corridor
Chapter 2.0 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-17 September 2016

Figure 2-13: West Connector Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-18 September 2016

Figure 2-14: West/East Corridor
Chapter 2 Alternatives Considered

Atlanta–Chattanooga HSGT Tier 1 DEIS 2-19 September 2016

Figure 2-15: West/East Connector Corridor
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-20 September 2016

2.2 Corridor Screening Process and Results

The screening process was the basis for evaluation of the 15 corridors developed during the Tier 1 

EIS Scoping Process. The purpose of the screening process was to identify Corridor Alternatives to 

evaluate further in this Tier 1 DEIS. Corridor alternatives to be further evaluated in the Tier 1 process 

are those that meet the Project goal to Improve Regional Mobility without requiring actions that are 

beyond what is possible or achievable given acceptable practice and funding constraints. The 

objectives of the Improve Regional Mobility goal, as described in Section 1.6.1, at the time of 

screening were as follows:

 Enhance Project Area and intercity mobility 

 Provide an alternative mode to auto travel and ease regional traffic congestion

 Provide a reduction in travel time within and between the major metropolitan areas of Atlanta 

and Chattanooga

 Provide intercity travel capacity to supplement over-used interstate highways

 Meet future intercity travel demand that will be unmet by existing transportation systems, and 

increase capacity for intercity mobility

 Maximize intermodal connections with local transit, major airports and highways

 Support population and employment growth through improved access to HSGT service

The Project Team evaluated corridor alternatives against criteria (or measures of effectiveness 

[MOEs]) that addressed the Project needs and goals listed above. A corridor was determined 

reasonable if it would provide improved mobility through competitive travel times and enhanced 

accessibility to population and employment centers in the Project Area. The Project Team 

considered these MOEs quantifiable and believed that they effectively captured the overarching 

mobility needs of the Project for travel efficiency and accessibility to a significant portion of potential 

users. The screening process utilized an un-weighted five-point scoring system, shown in Table 2-3. 

The scoring method was vetted and approved by the Project stakeholder committee, as well as the 

FRA. Scoring was assigned based upon how a corridor performed relative to the Project purpose 

and need. The Project Team assigned higher scores to those corridors: 1) with faster travel times 

for trips between HJAIA and downtown Chattanooga; 2) that contained a larger population within 10 

miles of each proposed station; and 3) for which a larger number of jobs are located within 5 miles of 

each proposed station. Table 2-4 shows the scores for each corridor evaluated. The Project Team 

advanced to Step 2 for further evaluation of all corridors that scored at or above 3.1, which indicated 

that the corridor sufficiently met the purpose and need of the Project to warrant additional study. See 

the Corridor Screening Process & Results Report in Appendix B for more information on the 

screening process.

Table 2-3: Corridor Screening Criteria Scoring and Rating System

Score Rating Performance Relative to the Best Performing 

Corridor* for Each MOE

4.1 – 5.0 Best Between 100 and 91% of best performing corridor

(including the best performing corridor)

3.1 – 4.0 Very Good Between 90 and 81% of best performing corridor

2.1 – 3.0 Good Between 80 and 71% of best performing corridor

1.1 – 2.0 Fair Between 70 and 61% of best performing corridor

0.0 – 1.0 Poor 60% or less of best performing corridor

* There may be more than one best performing corridor.
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-21 September 2016

Table 2-4: Corridor Screening Results – Summary of Corridor Performance

Corridor

Mobility MOE Scores Mobility MOEs 

Average Score

Advance to 

Step 2

Yes/No

Travel 

Time Population Employment

I-75 Terminal I-285 4.2 3.9 2.3 3.5 Yes

I-75 Southern Crescent NS 3.9 4.6 4.8 4.4 Yes

I-75 Southern Crescent 4.0 4.6 4.8 4.5 Yes

East Terminal I-285 3.1 3.9 2.1 3.0 No

East Southern Crescent NS 2.7 4.6 4.6 4.0 Yes

East Southern Crescent 2.9 4.6 4.6 4.0 Yes

I-75/West 5.0 1.0 1.0 2.3 No

I-75/Rome Split 3.3 1.0 1.0 1.8 No

I-75/Rome Terminal I-285 2.0 4.2 2.5 2.9 No

I-75/Rome Southern Crescent NS 1.6 5.0 5.0 3.9 Yes

I-75/Rome Southern Crescent 2.0 5.0 5.0 4.0 Yes

West 4.4 1.0 1.0 2.1 No

West Connector 1.0 1.0 1.0 1.0 No

West/East 4.4 1.0 1.0 2.1 No

West/East Connector 1.0 1.0 1.0 1.0 No

*Shaded rows with bold, italic text signifies corridors that did not advance to Step 2 because they did not score higher than 3.1

The following six corridors performed at or above 3.1 and advanced for further evaluation in the 

screening process:

 I-75 Southern Crescent NS;

 I-75 Southern Crescent;

 East Southern Crescent NS;

 East Southern Crescent;

 I-75/Rome Southern Crescent NS; and

 I-75/Rome Southern Crescent.

The Project Team eliminated the I-75 Terminal I-285 Corridor because it did not satisfy the purpose

and need. Specifically, the I-75 Terminal I-285 Corridor would not:

 provide access to the major activity center of downtown Atlanta;

 provide rapid, convenient, and reliable transportation between major population and employment 

centers;

 provide an optimal connection to the existing MARTA heavy rail transit system at the Five Points 

Station; or

 connect to the planned multi-modal passenger terminal (MMPT) in downtown Atlanta including 

the planned commuter rail and bus services serving the MMPT. 

The remaining eight corridors did not advance because each had an average MOE score of 3.0 or 

lower and, therefore, did not sufficiently meet the Project’s purpose and need. In particular, the I75/West, I- 75/Rome Split, West, West Connector, West/East, and West/East Connector Corridors 

demonstrated the lowest performance with regard to the mobility MOEs. Therefore, these corridors 

were not recommended for advancement for further Tier 1 EIS analysis. Moreover, stakeholder 

feedback provided subsequent to the scoping and screening processes included opposition to these 

corridors.
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-22 September 2016

For reasons detailed later in this chapter, this Tier 1 DEIS retained the three NS corridors (I-75 

Southern Crescent NS, East Southern Crescent NS, and I-75/Rome Southern Crescent NS), but 

detailed analyses of the three NS corridors will be deferred to future studies as design options for the 

Atlanta area. See Section 2.3.2 for a discussion of the NS design options.

In summary, the screening process identified three corridors that met the mobility and accessibility 

element of the purpose and need. These three corridors are deemed to be reasonable per CEQ 

requirements for developing and evaluating Project alternatives and are advanced in this Tier 1 

DEIS for further analysis:

 I-75 Southern Crescent Corridor;

 East Southern Crescent Corridor; and

 I-75/Rome Southern Crescent Corridor.

2.3 Definition of Alternatives

This section describes the alternatives that were evaluated in this Tier 1 DEIS.

2.3.1 No-Build Alternative

Federal regulations require that a No-Build Alternative be evaluated in an EIS (see 40 C.F.R. § 

1502.14(d)). The No-Build Alternative is the set of baseline conditions against which the other 

alternatives are compared. The No-Build Alternative assumes that there would be no Project-related 

elements in the Project Area. However, the No-Build Alternative assumes that all transportation 

system improvements currently listed in local, regional, and state transportation plans and that have 

identified funds for implementation will be implemented, with the exception of the Project. Thus, the 

No-Build Alternative represents the Project Area’s transportation system as it is anticipated to be in 

the 2035 and 2040 planning horizon years for each of the transportation plans for the individual 

MPOs within the Project Area. It includes the existing transportation system and assumes the 

implementation of highway and transit projects that are programmed and funded in the 

Transportation Improvement Program (TIP) element of the LRTP’s listed below. 

 Atlanta Regional Commission’s PLAN 2040 Regional Transportation Plan (2010)

 CHCRPA’s 2040 Long-Range Transportation Plan (2014)

 Rome/Floyd County MPO Long Range Transportation Plan 2040 (2012)

 Floyd-Rome Urban Transportation Study Urban Transportation Study (2011)

 Greater Dalton MPO’s 2035 Long Range Transportation Plan (2010)

As the airport development process is distinct from the surface transportation project development 

process documented in the TIPs, aviation projects considered as part of the No-Build Alternative 

were identified from the HJAIA 2015 Master Plan (HJAIA), Master Plan Update Chattanooga 

Metropolitan Airport (CMA 2010), and from local comprehensive transportation plans (CTPs) that 

include improvement and expansion projects for the local airports. The existing transportation 

system serving the Project Area can be summarized as follows:

 The highway system consists primarily of Interstate highways I-75, I-285, and I-24, and of 

highways US 27, US 411, and US 41. 

 The Intercity bus transit service is provided by Greyhound and Megabus. Local and regional bus 

transit service is provided within metropolitan Atlanta by MARTA, Cobb Community Transit 

(CCT), and Gwinnett County Transit (GCT). The Georgia Regional Transportation Authority 

(GRTA) provides regional commuter “Xpress” bus service. Local bus service is provided by the 
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-23 September 2016

Chattanooga Area Regional Transportation Authority (CARTA) and the City of Rome Transit 

Department (RTD). MARTA also includes a 48-mile heavy rail transit system with 38 stations. 

 The aviation system consists of two airports that currently provide passenger carrier service to 

the region: HJAIA and CMA.

Tables 2-5 through 2-7 list the projects included in the No-Build Alternative and is divided into 

highway, transit, and aviation sections.

Table 2-5: Highway Projects

MPO / Project 

Identification 

Number

Project 

Number P.I. 

Number

Project Description Model Year

Estimated 

Cost

($millions)

ARC / AT-076B 721750 US 41 (Northside Drive) Operations And Safety

Improvements (North Ave. To Marietta Street) 2030 $4.1

ARC / AT-268 0007557 US 41 (Northside Drive) Scoping And Engineering

Analysis (Whitehall St/I-20 To I-75) 2020 $8.0

ARC / AR-ML930 0008256

Northwest Corridor Managed Lanes At Akers Mill 

Road To Hickory Grove Road On I-75 And From I-75 

To Sixes Road On I-575

2020 $1,061.7

ARC / CO-041 0010510 US 41 From Windy Ridge Parkway To SR 120 Loop 

(North Marietta Parkway) 2030 $1.0

ARC / CO-443 0012607 US 41 (Cobb Parkway) Intersection Improvements @ 

SR 120 2020 $1.2

ARC / CO-444 0012608 US 41 (Cobb Parkway) Intersection Improvements @ 

SR 120 2020 $0.3

Dalton / 10 & 

13 611180 I-75 At SR 201, Widen I-75 2016 to 2025 $1.5

Dalton / 3 631360 SR3/US 41 Widening 2016 to 

2025 $22.7

CHCRPA / 47 NA Widen I-75 from 6 lanes to 8 lanes from SR 146 to 

TN state line 2030 $31.5

CHCRPA / 48 NA Widen I-75 from 6 lanes to 8 lanes from SR 2 to SR 

146 2040 $105.2

CHCRPA / 114 NA Widen I-75 6 to 8 lanes; fix structurally deficient 

bridge at southern portion of I-24 interchange 2030 $27.1

CHCRPA / 88 NA US 27/I-24 Widen from 4 to 8 Lanes for 1.5 miles

CST 

scheduled 

for 2017

$97.6

Bartow County 0013238

US 411 Connector from SR 20 / SR 3/ US 41 to I-75 

including I-75 Interchange – 7.31 miles of new 

roadway construction 

N/A N/A

Rome 632760 SR 101 Widening 2017 $4.3
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-24 September 2016

Table 2-6: Transit Projects

MPO / Project 

Identification 

Number

Service Type Project Description Year

Estimated 

Cost

($millions)

ARC / CO-401 Bus Transit 

Facilities

Park and Ride Facilities for Xpress Bus Service serving 

north Cobb. 2020 $15.0

ARC / AR-400 Multi-modal 

Service Georgia Multimodal Passenger Terminal (MMPT) 2030 $522.3

ARC / AR-480 Rail Service Amtrak Station Relocation to Intersection of US 41 

(Northside Drive) And 17th Street 2030 $35.0

ARC / AR-475 Transit –

Premium Bus

Connect Cobb / Northwest Atlanta Transit Corridor Bus 

Rapid Transit - Phase 1 2040 $500.0

CHCRPA / 

136 Local service GA portion of new local bus service connecting Fort Oglethorpe, GA to Downtown Chattanooga via US 27. 2020 $9.3

CHCRPA / 

138

Transit –

Premium Bus

Extend CARTA Express Route 4 further north on I-75 to 

Lee Highway 2020 $3.0

CHCRPA / 

139

Transit –

Premium Bus

New Premium Bus express route connecting Ringgold, GA 

with Downtown Chattanooga via I-75 and I-24 2030 $49.2

CHCRPA / 

137 Local service

New local bus service connecting East Ridge, TN to 

Downtown Chattanooga via US 41. Also goes slightly into 

North GA.

2040 $46.4

Table 2-7: Aviation Projects

Airport Project Name Project Description Open Year

Estimated 

Cost

($millions)

HJAIA South Gate 

Complex

70 additional aircraft gates with an APM connection to the 

expanded main terminal and an reconstruction of the 

existing terminal access roadway and the roadway 

extension south of I-285. 

2015 $1,800.0

CMA

Runway 02 and 

Taxiway A 

Extension Design 

and Construction

A 1,199-foot extension to Runway 02/20 and the 

associated extension of parallel Taxiway A. 

2013 –

2017 $11.5

CMA

North GA Apron 

Expansion Design 

and Construction 

A 7,250 square yard expansion to the North GA (general 

aviation) apron. 

2013 –

2017 $0.04

CMA

Terminal 

Concourse 

Expansion Design 

and Construction

A two-story extension of the terminal concourse. It 

includes the addition of three passenger-boarding 

bridges. 

2013 –

2017 $14.8

CMA

Terminal Loop 

Road Widening 

Design and 

Construction

Widen the terminal loop road. 2013 –

2017 $0.1

CMA

Consolidated 

Rental Car QTA 

Design and 

Construction 

A consolidated rental car Quick-Turn–Around (QTA) 

facility. 

2013 –

2017 $3.3

CMA Taxiway K Design 

and Construction Widen Taxiway K from 50 feet to 75 feet. 2027 $0.4
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-25 September 2016

2.3.2 Corridor Alternatives

Like the No-Build Alternative, the Corridor Alternatives also assume the implementation of the 

transportation system improvements that are currently listed in local, regional, and state 

transportation plans and that have identified funds for implementation. The three corridors that 

advanced to become Corridor Alternatives are I-75 Southern Crescent, East Southern Crescent, and 

I-75/Rome Southern Crescent, as illustrated in Figure 2-16. To streamline the naming convention 

used in subsequent chapters of this Tier 1 DEIS, the phrase “Southern Crescent” will be omitted as it 

applies equally to all. 

For this Tier 1 DEIS, the Corridor Alternatives are 1,000 feet in width. The buffer area allows for 

variation in the alignments to be determined during future analyses and is sufficiently wide enough to 

evaluate the potential environmental issues associated with the alternatives. The potential station 

locations presented are conceptual and are intended to indicate general areas to be served by the 

alternative, not specific sites of stations. Even at HJAIA and CMA, the specific location of stations in 

regards to the layout of these airports is not part of this analysis. Exact locations of potential stations 

will be determined during the Tier 2 NEPA process.

I-75 Corridor Alternative: The I-75 Corridor Alternative corridor begins on the east side of HJAIA at 

the proposed HJAIA/Southern Crescent station, immediately adjacent to I-75, and follows I-75 to a 

point south of the proposed downtown Atlanta station. The corridor continues north underground 

through downtown Atlanta to I-75 north and uses the I-75 ROW to the proposed

Cumberland/Galleria station. The corridor continues north along the I-75 ROW to the proposed Town 

Center, Cartersville, and Dalton stations. North of I-24 in Tennessee, the corridor continues along 

the ROW of the W&A Line operated by CSX to proposed stations at CMA and in downtown 

Chattanooga. The configuration of a proposed alignment will be defined during the Tier 2 NEPA 

phase; formal coordination with CSX will be required for any proposed use of CSX ROW.

East Corridor Alternative: The East Corridor Alternative corridor follows the same alignment as the 

I-75 corridor to the proposed Cartersville station. North of the proposed Cartersville station, the 

corridor deviates from I-75 and continues along existing CSX rail ROW generally parallel to US 411, 

stops at the proposed Dalton-Chatsworth and CMA stations, and continues to the proposed

downtown Chattanooga station. Specific configuration of the alignment will be defined during the Tier 

2 NEPA phase and formal coordination with CSX will be required for any proposed use of CSX 

ROW.

I-75/Rome Corridor Alternative: The I-75/Rome Corridor Alternative corridor follows the same path 

as the I-75 and East corridors to the proposed Cartersville station. From the proposed Cartersville 

station, the corridor follows US 411 to Rome, continues north along the ROW of the H-Line operated 

by NS to rejoin I-75 between the proposed Cartersville and Dalton stations. The corridor continues 

north along the I-75 ROW to the proposed stations at Dalton and CMA and in downtown 

Chattanooga. Specific configuration of the alignment will be defined during the Tier 2 NEPA phase 

and formal coordination with NS will be required for any proposed use of NS ROW.
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-26 September 2016

Figure 2-16: Corridor Alternatives
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-27 September 2016

Proposed Station Areas and Vehicle Storage, Maintenance, and Inspection Facilities

Each of the Corridor Alternatives includes potential station locations, and storage and maintenance 

facilities. Stations would provide park-and-ride facilities with direct pedestrian connections to the 

stations. The exact location, station type and configuration will be developed during the Tier 2 NEPA 

phase. 

Sites for the storage, maintenance and inspection facilities have not been identified or studied as 

part of this Tier 1 DEIS. Depending on the fleet size, operating plan, and the services provided, a 

facility to support the proposed high-speed ground transportation in both Atlanta and Chattanooga 

could require approximately 100 acres for each site. For the purpose of this Tier 1 DEIS, it is 

assumed that the proposed project would include:

 A storage and heavy maintenance facility near the southern terminus in the vicinity of HJAIA. 

This facility also would include the command center for all systems and train wash facilities; and

 A storage and inspection yard near the northern terminus within the Chattanooga area. The

storage and inspection yard would provide facilities for running inspections, light duty repairs on 

equipment, as needed, and train storage. This yard also would include a control tower to control 

access to and within the yard. 

Corridor Attributes

The vertical alignments would vary along the routes of each Corridor Alternative between at-grade, 

elevated structure, and tunnel, depending on the topographic conditions and existing development 

within each Corridor Alternative. The exact alignment configuration will be defined during the Tier 2 

NEPA process. All Corridor Alternatives would be exclusive facilities that do not share track with 

other trains and are grade separated when crossing roadways or rail lines. Table 2-8 presents key 

attributes of each Corridor Alternative. In this Tier 1 DEIS, the Corridor Alternatives steel-wheel and 

Maglev technologies are assumed.

Table 2-8: Corridor Alternatives Attribute Comparison

Corridor Alternative

(Potential Number of 

stations)

Length of 

Alternative 

(miles)

Projected 2040 Total 

Daily Ridership*

(passengers)

Time to Travel 

Corridor End to End 

(minutes)**

I-75 (8) 128 11,725 88

East (8) 139 8,556 95

I-75/Rome (9) 150 13,204 102

* Appendix C, Ridership Forecasting Report, provides travel demand modeling information

** Based on a combination of Intercity, Intra-Atlanta, and Airport Choice models, as detailed in the Ridership Forecasting 

Report.

Atlanta In-Town Design Options

Within Atlanta, there are two optional ways to access the proposed Downtown Atlanta station, along 

the NS railroad corridor or I-75. Since the NS option would have virtually identical operational 

characteristics and potential environmental impacts as those following the I-75 segment within the 

city of Atlanta (as shown in Table 2-9), the Project Team has deferred the consideration of potential 

alignment configurations for the Downtown Atlanta Stations to the Tier 2 NEPA phase. Figure 2-16

shows the NS design option within Atlanta. The NS option would have the same proposed station 

locations, ridership, capital costs, population, and employment would be virtually the same as the 

Corridor Alternatives described above. Per NEPA and FRA guidance, the goal of this Tier 1 DEIS is 

to identify a corridor in which to implement the proposed service and to evaluate potential 
Chapter 2 Alternatives Considered

Atlanta-Chattanooga HSGT Tier 1 DEIS 2-28 September 2016

environmental impacts at a broad level. As such, folding in those corridor alternatives following the 

NS segment with those following the I-75 segment during this Tier 1 DEIS would not preclude the 

potential consideration of alignments following the NS segment during future, Tier 2 NEPA analyses. 

Table 2-9: Characteristics of the Southern Crescent Corridors

Resource Area I-75 I-75 NS East East NS I-75/ 

Rome

I-75/ 

Rome NS

Time to Travel Corridor, End to End 

(minutes) 84 86 93 95 102 104

Alignment within an Existing Transportation 

Corridor (percent)

76 73 31 29 53 51

Parklands and Wildlife Refuges (acres) 443 400 447 398 442 392

Known Archaeological Resources 

(number) 24 24 44 44 39 39

Known Historic Resources (number) 22 23 57 58 31 32

National Register of Historic Places Sites 

(acres) 87 106 151 170 89 108

Known Civil War Battle Sites (acres) 3,670 3,899 2,350 2,550 3,834 4,034

Cemeteries (number) 3 3 2 2 4 4

Wetlands (acres) 205 205 205 205 251 251

Stream Crossings (number) 21 19 18 17 32

Floodplains (acres) 1,563 1,536 2,576 2,549 1,688 1,661

Known Threatened and Endangered 

Species Habitats (number)

21 21 38 38 21 21

Known Threatened and Endangered 

Species Habitat (acres)

1,907 1,907 2,158 2,158 1,817 1,817

SOURCES: AECOM; US Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI); U.S. Census Topologically 

Integrated Geographic Encoding and Referencing (TIGER); Digital Flood Insurance Rate Map (DFIRM); Federal Emergency 

Management Agency (FEMA) Quadrangle 3 (Q3) data; National Register of Historic Places (NRHP) (USDOI NPS 2011); Georgia 

Department of Natural Resources (DNR) survey; Tennessee Historic Commission survey; Georgia’s Natural Archaeological 

Historical Resources Geographical Information System (NAHRGIS) database; the Georgia Historic Bridge Survey (GHBS) (GDNR 

2011); 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-1 September 2016

3.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL 

CONSEQUENCES

3.1 Introduction

This chapter describes the existing social, economic, and environmental conditions in the Project 

Area and describes the potential for permanent and temporary (construction-related) impacts of the 

Corridor and No-Build Alternatives. The assessment of impacts is primarily qualitative based on 

readily available data. Environmental consequences will be further defined in the Tier 2 NEPA 

process if a Preferred Corridor Alternative is selected for further evaluation. Secondary and 

cumulative effects are broadly described at the end of this chapter; in-depth analysis will occur 

during the Tier 2 NEPA process. This chapter also presents potential strategies to avoid or minimize 

and mitigate the effects of the Project. Specific mitigation commitments for the selected alternative 

will be determined during the Tier 2 NEPA phase. 

The methodology FRA, GDOT and TDOT used in assessing the potential effects of the Corridor and 

No-Build Alternatives on the social, economic, and environmental resources that are reported in this 

Tier 1 DEIS is in accordance with federal regulations and guidelines. 

The issues and resources listed below are the focus of this Tier 1 DEIS. These issues and resources 

were assessed in this Tier 1 DEIS for three reasons: they occur in the Project Area, a determination 

of Project effects on these resources can be made at the current program level of evaluation, and 

potential effects on these resources may vary among the alternatives and assist FRA, GDOT, and 

TDOT in selecting the best alternative to advance to further study.

 Transportation: ridership, existing 

transportation corridors, traffic

 Air Quality: overall air quality effects 

 Noise and Vibration: noise and vibration 

effects 

 Socioeconomics and Environmental 

Justice: population access, employment 

access, effects on minority and lowincome populations 

 Parklands, Recreational Areas, and 

Wildlife Refuges

 Cultural Resources: historic and 

archeological resources

 Water Resources: streams and lakes, 

floodplains, wetlands, water quality

 Biological Resources: threatened and 

endangered species and critical habitat

Due to the broad scope of this study and because they would not be a determining factor in the 

selection of a Preferred Corridor Alternative, the following resources were not evaluated in this Tier 1 

EIS : solid waste disposal, energy, impacts to mobility of elderly and disabled, and public health and 

safety. 

The issues and resources that will be assessed and analyzed in the Tier 2 NEPA phase will require 

a site-specific design and more precise discussion of the direct and indirect effects within the Project 

Area than is possible in a broad, corridor level assessment. During the Tier 2 NEPA analysis, and if 

a Corridor Alternative is selected, site-specific research, fieldwork, and effects analysis will be 

performed on all issues and resources in compliance with NEPA and FRA guidelines, and other 

federal and state laws. 

Each section in this chapter describes the affected environment and potential consequences due to 

the Project. A “Subsequent Analysis” discussion describes the analysis that FRA, GDOT, and TDOT 

will undertake during the Tier 2 NEPA phase.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-2 September 2016

3.2 Summary of Key Findings

The Tier 1 analysis of environmental consequences described in this chapter determined that the 

Project, as well as the No-Build Alternative projects described in Section 2.3.1, have the potential to 

affect the human and natural environment. 

No-Build Alternative: The extent to which the planned and funded projects in the No-Build 

Alternative would have impacts on the human and natural environment and whether those impacts 

could be avoided or minimized can only be determined through environmental analysis to be 

undertaken by the sponsors of those projects. See Tables 2-5, 2-6, and 2-7 for a list of the planned 

and funded projects. Key findings of this Tier 1 assessment are that the No-Build Alternative:

 Would increase capacity and expand service in selected portions of the Project Area 

transportation network, but would not enhance passenger mobility throughout the Project Area 

between the metropolitan areas and airports of Atlanta and Chattanooga; 

 Would not adequately address the transportation needs of projected population and employment 

growth in the Project Area, would not increase transportation options, would not increase airport 

and intermodal connections, would not fully address transportation limitations on economic 

growth, and would not provide faster and more reliable ground transportation as an alternative to 

highway, intercity bus and air travel; 

 Would not improve air quality because it would not reduce the quantity or the growth rate of 

mobile source emissions resulting from vehicle miles traveled on the highway network in the 

Project Area; and

 Potentially would have impacts on communities, parks, wildlife refuges and recreational areas, 

cultural resources, water and biological resources.

Corridor Alternatives: Key findings of the Tier 1 assessment are that the Corridor Alternatives:

 Would improve mobility and accessibility in the Project Area; 

 Would address some of the transportation needs of projected population and employment 

growth in the Project Area, particularly in terms of increasing transportation options, increasing 

airport and intermodal connections, address transportation limitations on economic growth, 

provide faster and more reliable ground transportation as an alternative to highway, intercity bus 

and air travel; 

 Would improve air quality by providing a transportation option that does not increase the quantity 

or the growth rate of mobile source emissions resulting from vehicle miles traveled on the 

highway network in the Project Area; and

 Would potentially have impacts on communities, parks, wildlife refuges and recreational areas, 

cultural resources, water resources, and biological resources.

In regard to potential human and natural environment impacts, the Tier 1 analysis revealed several

differences among the Corridor Alternatives:

 Ridership: The I-75/Rome Corridor Alternative would have the highest ridership, followed by the 

I-75 Corridor Alternative; the East Corridor Alternative would have the lowest ridership.

 Travel Time: End to end travel times vary among the Corridor Alternatives with the I-75 Corridor 

Alternative being the shortest at 88 minutes, East Corridor Alternative at 95 minutes, and the I75/Rome Corridor Alternative at 102 minutes.

 Transportation: The I-75 Corridor Alternative would use the most existing transportation right-ofway (ROW), followed by the I-75/Rome Corridor Alternative. The East Corridor Alternative would 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-3 September 2016

use the least existing transportation ROW, thereby having the highest potential for effects 

according to this measure.

 Air Quality: The I-75/Rome Corridor Alternative has the highest potential to transfer trips from the 

highway system to the proposed HSGT and, thereby, reduce vehicular emissions. This finding is 

based solely on ridership. The I-75 Corridor Alternative would perform slightly less well, followed 

by the East Corridor Alternative having the lowest potential.

 Noise and Vibration: All Corridor Alternatives would have potential noise and vibration impact. 

The I-75 Corridor Alternative is the best performing for both noise and vibration on sensitive land 

uses within their respective screening distances. This may be attributed to the fact that a longer 

length of the I-75 Corridor Alternative is adjacent to the interstate highway system, whereas the 

other two alternatives deviate from the interstate and travel along U.S. highways (which tend to 

have more development located closer to the roadway than interstate highways).

 Population and Employment Access: County-based 2010 U.S. Census data demonstrate that 

the more urbanized areas typically have higher densities of minority and low-income populations 

compared with rural areas. The ratio of environmental justice (EJ) areas to non-EJ areas within 

each Corridor Alternative when measured by linear mile along each corridor is 0.6:1 for the I-75 

Corridor Alternative and 0.5:1 for the East and I-75/Rome Corridor Alternatives. Moreover, not all 

Corridor Alternatives serve the same proposed station locations or the same EJ populations. For 

example, only the I-75/Rome Corridor Alternative would serve the proposed Rome station area. 

Similarly, only the East Corridor Alternative would serve the proposed Dalton-Chatsworth station 

area. Therefore, depending on the Corridor Alternative, some EJ populations in the study area 

would be served and some would not.

 Parklands and Wildlife Refuges: While the potential affected acreage for the Corridor 

Alternatives is relatively even, the number of Parks and Wildlife Refuges is different. I-75 East is 

the best performing, while I-75 and I-75/Rome Corridor Alternatives each have the potential to 

affect over 25 Parks and/or Wildlife Refuges each. Note that these numbers are based on very 

small portions of the 1000’ buffer touching these parks. The main resources potentially affected 

are virtually identical.

 Historic Resources: The East Corridor Alternative has twice the number of known historic 

resources as the I-75 or I-75/Rome Corridor Alternatives. The higher number is due to the East 

Corridor Alternative using a lower percentage of existing transportation rights-of-way. This 

differentiating factor suggests the potential for a higher number of Project impacts on known 

historic resources if the East Corridor Alternative is advanced.

 Wetlands, Streams, and Floodplains: Also using a lower percentage of existing rights-of-way, the 

I-75/Rome Corridor Alternative would potentially affect more acres of wetlands and introduce 

new or expanded stream crossings than the other Corridor Alternatives. This difference suggests 

the potential for a higher number of Project impacts on wetlands, and streams if the I-75/Rome 

Corridor Alternative is advanced. The East Corridor Alternative has a considerably higher 

acreage of floodplains compared with the other alternatives.

 Known Threatened and Endangered Species Habitats: The East Corridor Alternative has a 

larger number of known threatened and endangered species habitats within the buffer area than 

the I-75 and I-75/Rome Corridor Alternatives. This differentiating factor suggests the potential for 

a higher number of Project impacts on known threatened and endangered species habitats if the 

East Corridor Alternative is advanced.

Table 3-1 summarizes the data findings for the Corridor Alternatives; these data are discussed in the 

remaining sections of this chapter.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-4 September 2016

Table 3-1: Comparative Summary of the Corridor Alternatives

Needs Measures Corridor Alternative

I-75 East I-75/Rome

Enhance regional 

transportation mobility 

and accessibility

Time to Travel Alternative End 

to End (minutes) 88 95 102

Population within 10 miles of 

Proposed Station Locations 

(millions)

2.85 2.86 2.95

Employment within 5 Miles of 

Proposed Station Locations 

(thousands)

869 870 894

Daily Ridership 

(number of boardings) 11,725 8,556 13,204

Spur economic growth 

and regional vitality Capital Cost (2014$ millions) $8,760 $10,420 $9,811

Provide safe, efficient, 

reliable transportation

Provide passenger rail service 

on exclusive rail/guideway Yes Yes Yes

Enhance airport 

access and intermodal 

connections

Provide access to HJAIA and 

CMA; connect to MARTA, 

GRTA and CCT service areas

Yes Yes Yes

Improve air quality 

nonattainment areas 

and minimize 

environmental impacts

Proportion of Corridor 

Alternative within Existing 

Transportation Corridor 

(percent)

76% 31% 53%

Noise-sensitive Land Uses 

(acres) 5,914 7,519 8,425

Vibration-sensitive Land Uses 

(acres) 891 1,695 1,372

Ratio of EJ areas to overall 

corridor (based on linear miles) 0.6:1 0.5:1 0.5:1

Ratio of Station Areas with and 

without EJ populations 6:2 6:2 6:2

Parklands and Wildlife Refuges 

(acres)

443 447 442

Parklands and Wildlife Refuges 

(number)

25 19 30

Known Archaeological 

Resources (number) 32 46 38

Known Historic Resources 

(number) 26 66 33

Cemeteries (number) 4 3 5

Wetlands (acres) 205 205 251

Stream Crossings (number) 21 18 35

Floodplains (acres) 1,563 2,576 1,689

Known Threatened and 

Endangered Species Habitats 

(number)

21 38 21

Known Threatened and 

Endangered Species Habitats 

(acres)

1,907 2,158 1,817

In summary, despite the differences among the Corridor Alternatives, each Corridor Alternative 

demonstrates some level of achievement of the Project purpose based on the data available at this 

Tier 1 level of study. The East Corridor Alternative has the highest potential for impacts on known 

historic resources and floodplains, while the I-75/Rome Corridor Alternative has the highest potential 

to impact wetlands and stream crossings. Compared to the other Corridor Alternatives, the I-75 

Corridor Alternative has the lowest potential for impact on known historic resources, streams, and 

floodplains; impacts on wetlands are similar to the East Corridor Alternative.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-5 September 2016

3.3 Transportation

This section describes the existing roadway, public transit, freight rail, and air transportation facilities 

and services within the Project Area, discusses the potential transportation effects of the corridor 

alternatives and the No-Build Alternative, and identifies potential measures to avoid, minimize, or 

mitigate these effects. Of the transportation factors considered, three are distinguishing factors 

among the alternatives: travel time, ridership, and the proportion of corridor alternative within an 

existing transportation corridor.

3.3.1 Legal and Regulatory Context

The effects of the alternatives on both passenger and freight transportation were broadly considered 

in this Tier 1 DEIS using FRA’s Environmental Procedures as guidance. 

3.3.2 Methodology

3.3.2.1 AutoTraffic Modeling

Existing traffic data represented by the level of service (LOS) and average daily traffic (ADT) of the 

roadway and airway corridors were obtained for 29 segments. Highway capacity analysis was 

conducted by GDOT and TDOT to determine the future LOS and roadway capacity requirements 

projected to 2040. LOS is a measure used to describe operational conditions within a traffic stream. 

There are six levels identified by the letters A through F. LOS A represents free flow traffic where 

drivers are virtually unaffected by the presence of other vehicles, while LOS F represents operating 

conditions in which demand exceeds capacity. The LOS and the ADT were determined for the base 

year 2010 and 2040.

The functional classification and the operating characteristics of segments of I-75 and US 411 were 

studied because portions of these roadway corridors would be used by the three Corridor 

Alternatives. 

3.3.2.2 Transit Modeling

Ridership was forecast using a travel demand model to estimate the number of rail trips between 

stations (using general station locations only for modeling purposes) (See Appendix C - Ridership 

Forecasting Report for a detailed description of the methodology to estimate travel demand). The 

HSGT demand-forecasting model considered four distinct travel segments:

 Inter-City: trips from one of the corridor’s four major sub-areas10 to another sub-area

 Intra-Atlanta:

o Main Intra-ARC (inside the Atlanta Regional Commission’s [ARC] transportation planning 

area): trips from one location to another in the ARC region, excluding trips by air travelers 

to/from the Hartsfield-Jackson Atlanta International Airport (HJAIA)

o Airport Access: trips by air travelers in the ARC region to/from HJAIA

 Airport Choice: trips by air travelers to/from the Chattanooga Metropolitan Airport (CMA)

For each Corridor Alternative, data on the areas where the stations are proposed (as described in 

Section 2.3.2), estimated travel times, proposed fare structure and demographic data were used as 

inputs to the HSGT Project model. The HSGT Project model produced the number of trips that would 

 

10 The four sub-areas include the four MPO-level travel demand forecasting model systems used to create the overall model: The 

ARC 20-county model, the Greater Dalton MPO model (Dalton and Whitfield Counties, GA) model, the Rome-Floyd MPO model, 

and the Chattanooga-Hamilton County-North Georgia (CHCNGA) area model. 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-6 September 2016

be diverted to the proposed HSGT service from all three travel markets listed above. Travel time 

calculations include all proposed stops, plus a dwell time at terminal stations of 1.5 minutes and 3.0 

minutes at each intermediate station. 

3.3.3 Affected Environment

Roadways in Project Area

Table 3-2 lists the roadway segments and their functional classifications that generally parallel one 

or more of the Corridor Alternatives. According to the Federal Highway Administration (FHWA), 

“Functional classification is the process by which streets and highways are grouped into classes, or 

systems, according to the character of traffic service that they are intended to provide. There are 

three highway functional classifications: arterial, collector, and local roads. All streets and highways 

are grouped into one of these classes, depending on the character of the traffic (i.e., local or long 

distance) and the degree of land access that they allow.” (2012) The classifications are described 

below.

 Arterial: Provides the highest level of service at the greatest speed for the longest uninterrupted 

distance, with some degree of access control.

 Collector: Provides a less highly developed level of service at a lower speed for shorter 

distances by collecting traffic from local roads and connecting them with arterials.

 Local: Consists of all roads not defined as arterials or collectors; primarily provides access to 

land with little or no through movement.

Table 3-2: Roadways that Generally Parallel the Corridor Alternatives

Roadway 

Segment Functional Classification Segment(s)

I-75

Urban Interstate Principal 

Arterial

Passes HJAIA in northwest Clayton County, continues through 

Fulton, Cobb, and Cherokee counties, as it enters Bartow County; 

within the urban limits of Calhoun, Dalton, and Ringgold, and in 

Hamilton County as it enters Tennessee.

Rural Interstate Principal 

Arterial Through Bartow, Gordon, Whitfield, and Catoosa Counties 

US 41

Urban Minor Arterial

Atlanta region until it crosses Ralph David Abernathy Boulevard; 

From I-285 to Cartersville; within the urban limits of Calhoun, 

Dalton, and Ringgold.

Urban Principal Arterial

From Ralph David Abernathy Boulevard to I-75; from the Cobb 

Parkway interchange to the north until it crosses I-285; within the 

limits of Cartersville; between US 76 and I-75 in Dalton and for a 

short section in Ringgold between the intersection of SR 146 and 

the state line

Rural Minor Arterial

As it leaves Cartersville, it becomes and remains in this 

classification except within the urban limits of Calhoun, Dalton and 

Ringgold

US 411 west of 

Cartersville

Urban Interstate Principal 

Arterial

From its interchange with I-75 to the western side of the 

Cartersville urban limits; within the urban limits of Rome

Rural Principal Arterial To the west of the Cartersville urban limits and into Floyd County

US 411 north of 

Cartersville Rural minor arterial

As it exits the urban limits of Cartersville and continues through 

Bartow, Gordon, and Murray counties until it joins US 78 in Murray 

County

Source: ARC 2010, Rome-Floyd County MPO 2012, and TDOT 2015

Current and Projected Highway Operating Characteristics

The current and projected levels of congestion on the existing roadway network in 2010 and 2040 

are summarized in Table 3-3, which presents the LOS at representative points on the roadway 

network between Atlanta and Chattanooga. 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-7 September 2016

Table 3-3: Level of Service on Major Routes in the Project Area (2010 and 2040)

Roadway Analysis Points LOS Roadway Analysis Points LOS

2010 2040 2010 2040

I-75 South of I-285 (Clayton County) E C

1 US 41 North of I-75 E E

I-75 North of I-285 E E

1 US 41 South of I-20 B B

I-75 North of US 41 D E US 41 South of 14th St. E C

I-75 /I-85 South of I-20 E F US 41 South of I-285 (Cobb County) B B

I-75 /I-85 South of 14th Street E F US 41 South of SR 280 C C

I-75 South of I-285 (Fulton County) E

1

F

1 US 41 North of Chastain Road F E

I-75 South of SR 280 E F US 41 North of SR 92 C C

I-75 South of I-575 E F US 41 South of SR 53 A A

I-75 North of Chastain Road E D

1 US 41 North of SR 136 C C

I-75 North of Wade Green Road D F US 41 North of Carbondale Rd. A

2 C2

I-75 North of Glade Road D E US 41 North of SR 201 A

2

A

2

I-75 South of SR 140 B C US 41 North of SR 146 A A

I-75 South of SR 53 C D US 411 East of SR 1 Loop C

2 D2

I-75 North of SR 136 E E US 411 East of Biddy Road B

2 D2

I-75 North of Carbondale Road C

2 C2 US 411 East of Alford Road C D

I-75 North of SR 201 D

2 C2 US 411 East of Harden Bridge Road C D

I-75 North of US 41 / SR 3 E E US 411 South of Falling Springs Road D E

I-75 North of SR 146 E E US 411 North of Salacoa Road D E

I-285 North of SR 280 E F US 411 North of SR 136 C D

I-285 North of Paces Ferry Road E F US 411 South of SR 2 A A

US 41 South of I-285 (Clayton County) D E US 76 West of US 411 A A

US 41 North of I-285 (Clayton County) E B

1Denotes sections of roadway network with proposed Managed Lanes system.

2

LOS represents roadway segments provided by MPOs that have a base year different than 2010 or a future year different than 

2040. The base year and future year for the Greater Dalton MPO is 2006 and 2035, respectively, and 2009 and 2040, respectively 

for the Rome Floyd-County MPO.

Sources: Transportation Demand Models for ARC, Greater Dalton MPO, Chattanooga-Hamilton County Regional Planning Agency, 

and Rome-Floyd County MPOs 2013 and TDOT 2014

According to the analyses, with the exception of six roadway segments mostly located in rural areas,

I-75 would operate at LOS D or worse in 2040 throughout the Project Area. The six more rural 

roadway segments are projected to have a LOS ranging from A to C. Of the 18 segments analyzed 

along I-75, six would experience LOS F. These six segments are in metropolitan Atlanta.

US 411, with the exception of one segment, would operate at D or worse in 2040 at all points 

studied; the one segment with a LOS better than D is the section south of SR 2. Base and future 

year LOS trends on US 41 are generally the same. Traffic volumes and corresponding LOS vary 

from the southern end of the Project Area in Atlanta to near the Tennessee state line. In the 

southern portion of the Atlanta metropolitan area and Clayton County south of I-285, volumes are 

just under 50,000 cars per day with a LOS E. Volumes drop significantly south of I-20 with just over 

20,000 vehicles per day and a LOS A; however, volumes pick up significantly traveling further north 

all the way through the Cobb County area, north of I-285 with volumes over 76,000 vehicles per day 

and a LOS E. Volumes gradually drop traveling further north with a decrease in Bartow County with 

just under 3,000 vehicles per day and a LOS A. From there, volumes remain fairly low and constant 

to the Tennessee state line.

Figure 3-1 and Figure 3-2 present the LOS and ADT at all points studied for the years 2010 and 

2040. These data indicate that travel on Project Area roadways is affected by congestion in many 

locations. Travel times between Chattanooga and Atlanta are:

 Intercity bus – 125 to 185 minutes

 Automobile (on I-75) – 110 minutes (non-peak)
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-8 September 2016

Figure 3-1: Roadway Level of Service and Average Daily Traffic – South

Sources: Transportation Demand Models for ARC, Greater Dalton MPO, Chattanooga-Hamilton County Regional Planning Agency, 

and Rome-Floyd County MPOs 2013 and TDOT 2014
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-9 September 2016

Figure 3-2: Roadway Level of Service and Average Daily Traffic – North

Sources: Transportation Demand Models for ARC, Greater Dalton MPO, Chattanooga-Hamilton County Regional Planning Agency, 

and Rome-Floyd County MPOs 2013 and TDOT 2014
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-10 September 2016

The Texas Transportation Institute reported in their 2011 Urban Mobility Report that the Atlanta 

region is the 13th most congested area in the United States with an average of 43 hours lost per 

person annually in travel. As roadway congestion increases, intercity bus and automobile travel 

speeds on the roadway network will decrease, and travel times will increase. Because of these 

factors, the time it takes to travel between destinations, particularly by public transit that operates in 

mixed roadway traffic will become increasingly unreliable. 

Existing Transit Services

The following local and regional rail and bus transit systems operate in the Project Area:

 Metropolitan Atlanta Rapid Transit Authority (MARTA): During FY 2013, MARTA provided 

approximately 130 million passenger trips on 91 fixed bus routes and over 48 miles of heavy rail 

through 38 rail stations in Fulton and DeKalb counties (MARTA 2014). Rail service operates 5:00 

AM to 1:00 AM Monday through Friday, and weekends and holidays from 5:00 AM to 12:30 AM. 

Fixed routes bus service operates at various times seven days per week.

 Georgia Regional Transportation Authority (GRTA): In FY 2013, GRTA operated 175 buses

with 2 million passenger boardings, 55 vanpools, and 4 demand response vehicles. GRTA 

Xpress is a partnership between GRTA and the counties of Clayton, Cherokee, Cobb, Coweta, 

DeKalb, Douglas, Forsyth, Fulton, Gwinnett, Henry, Paulding and Rockdale. GRTA Xpress 

operates 33 commuter express routes, which connects to MARTA and other transit systems. 

(GRTA 2014)

 Cobb Community Transit (CCT): In 2013, CCT operated 101 buses, including 18 routes with 

express service on I-75, and 30 demand response vehicles providing an estimated 3.6 million 

annual trips to its riders. The service is offered 4:00 AM to midnight Monday through Saturday, 

excluding holidays (CCT 2014).

 City of Rome Transit Department (RTD): RTD operates 24 buses and 4 demand response 

vehicles providing approximately 830,000 annual trips within the City of Rome. Its services 

include 5 mainline regular routes; 15 tripper routes, which serve other areas for students of 

Rome City Schools and other riders; paratransit service for Americans with Disabilities Act 

(ADA)-qualified riders; and charter service within Floyd County. Buses operate 5:40 AM to 6:30 

PM Monday through Friday, excluding holidays (City of Rome RTD 2014). 

 Chattanooga Area Regional Transportation Authority (CARTA): CARTA operates 49 buses 

and 12 demand response vehicles providing 2.5 million annual trips. CARTA also operates the 

Lookout Mountain Incline Railway, the Downtown Electric Shuttle, and Care-A-Van service for 

people with disabilities with 17 routes operating seven days per week in Hamilton County

(CARTA 2014).

The following intercity bus services operate in the Project Area:

 Greyhound: Greyhound operates inter-city bus service between Atlanta and Chattanooga, with 

eight departures Monday through Saturday and six departures on Sundays. The trip takes 

between 1 hours 55 minutes and 2 hours 20 minutes. According to Greyhound, the standard 

adult fare is approximately $33.00 one-way and $66.00 round trip (2015). Ridership figures are 

not available.

 Megabus: Megabus operates inter-city bus service between Atlanta and Chattanooga, with four 

departures daily, including weekends. Each trip takes approximately 2 hours 5 minutes. The 

standard adult fare ranges from $5.00 to $11.00 each way. Ridership figures are not available.

As with automobile travel, bus travel times are affected by roadway congestion because buses 

operate with mixed traffic. As roadway congestion increases, intercity bus travel speeds on the 

roadway network will decrease, and travel times will increase. As a result of these factors, the time it 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-11 September 2016

takes to travel between destinations, particularly by public transit that operates in mixed roadway 

traffic will become increasingly unreliable.

Existing Air Transportation

The two major airports serving the Project Area are Hartsfield-Jackson Atlanta International Airport 

(HJAIA) and Chattanooga Metropolitan Airport (CMA). They are briefly described below.

Hartsfield-Jackson Atlanta International Airport (HJAIA)

 Aviation Travel Demand: HJAIA currently ranks first in the world in passenger arrivals and 

departures as well as scheduled flights, and ranks 13th in air cargo volume. HJAIA serves 156 

domestic destinations and more than 80 international destinations in 50 countries with 2,500 

daily flights. It serves approximately 250,000 passengers a day, or about 91.3 million 

passengers per year (HJAIA 2014).

 Airlines: Domestic passenger service is provided by 22 airlines, international passenger service 

by 15 airlines, and cargo service by 19 airlines. 

 Capacity: There are 29,550 public parking spaces, including 13,566 covered spaces, 7,800 

economy lot spaces, and 8,184 airport park/ride spaces. Additional parking to support the 

International Terminal was completed in 2011.

Chattanooga Metropolitan Airport (CMA) 

 Aviation Travel Demand: In 2013, about 618,000 passengers enplaned and deplaned at CMA. 

The top five origins and destinations of those passengers were Washington, D.C., New York, 

NY, Houston, TX, Philadelphia, PA and Boston, MA. CMA has non-stop flights to Atlanta, 

Charlotte, Chicago, Dallas, Detroit, Memphis, Washington DC, Orlando and Tampa / St. 

Petersburg. HJAIA is CMA’s number one connecting hub, accounting for 28 percent of 

Chattanooga’s local outbound travel. (CMA 2013)

 Airlines: Domestic passenger service is provided by four airlines. The airport does not offer 

international service.

 Capacity: CMA currently operates 5 commercial gates with plans to expand to 10 gates. The 

airport also has a general aviation facility operated by a fixed-base operator, with 16 acres of 

ready-to-build land available for general aviation expansion. The airport prepared a master plan 

update in 2010 (Master Plan Update – Chattanooga Metropolitan Airport), which calls for

improvements in parking, general aviation, cargo, and hydrologic conditions. There are 1,226 

public parking spaces, including 173 short-term spaces, 220 intermediate spaces, 739 long-term 

spaces, and the 94 employee spaces.

Air travel times between Chattanooga and Atlanta, including passenger ground time in the airports,

is 120 minutes (airport gate to gate). Additional air passenger travel time depends on origin,

destination, and airport processing.

Existing Rail Passenger and Freight Transportation

Within the Project Area, two freight railroads, CSX and Norfolk Southern (NS), connect the two 

cities; a third freight line connects Rome and Chattanooga; and a fourth line originally connected

Chattanooga and Gadsden, Alabama. The freight railroads that provide connections between the

Atlanta and Chattanooga regions are illustrated in Figure 3-3 and are described below. 

 Western and Atlantic (W&A): The most direct route connecting Atlanta and Chattanooga is the 

former W&A Railroad via Cartersville and Dalton. The W&A is owned by the State of Georgia 

and has been leased to CSX and its predecessors for over 100 years. This line is referred to as 

the W&A to distinguish it from other lines operated by CSX in northwestern Georgia.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-12 September 2016

Figure 3-3: Railroad Alignments within the HSGT Project Area
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-13 September 2016

 H-Line: An NS line connects Atlanta and Chattanooga via Austell, Rome, and Dalton where it 

crosses CSX (W&A) at grade. This line is known as the H-Line to distinguish it from other NS 

lines in northwestern Georgia as its mileposts have an H-letter suffix. The line was completed 

between Rome and Atlanta as part of East Tennessee, Virginia and Georgia that was later 

merged into the Southern Railway.

 C-Line: The C-Line is a NS line connecting Rome to Chattanooga via Summerville. The line is 

known as the C-Line to distinguish it from other NS lines in northwestern Georgia as its 

mileposts have a C-letter prefix. The C-Line has been abandoned between Bone and Lyerly. The 

portion between Lyerly and Chattanooga is owned by the State of Georgia and is leased to the 

Chattooga and Chickamauga Railway (CCKY) by their West District.

 TAG-Line: The Tennessee, Alabama and Georgia Railroad Line (TAG) connects Chattanooga 

to Gadsden via Hedges. The portion of the line south of Hedges has been abandoned. The 

portion of the line between Chattanooga and Hedges is leased by NS to the CCKY and is 

operated at their East District. This line is referred to as the TAG-Line to distinguish it from the CLine operated by the CCKY West District.

3.3.4 Environmental Consequences

3.3.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. The No-Build Alternative 

projects currently planned would increase roadway capacity, expand transit service, and improve 

transportation operations in selected portions of the Project Area transportation network, but would 

not enhance passenger mobility throughout the Project Area between the metropolitan areas and 

airports of Atlanta and Chattanooga. In comparison with the Corridor Alternatives, the No-Build 

Alternative projects would provide little benefit in the areas of:

 Increasing travel options;

 Reducing ground travel time;

 Increasing connections to existing transit services; and

 Increasing transit ridership.

The No-Build Alternative projects would not individually or collectively provide corridor-wide benefits 

in terms of faster and more reliable ground transportation service to the traveling public as an 

alternative to highway, intercity bus, and air travel.

3.3.4.2 Corridor Alternatives

Effects on Roadways

Travelers to destinations that would be served by the Project would have the option of using the 

proposed HSGT service as opposed to highway travel. In general, the Project is anticipated to 

benefit the Project Area roadway network as it would provide intercity travel capacity to supplement 

over-used interstate highways in the Project Area. 

Regionally, rider choice to use HSGT service as opposed to the existing roadway network would 

change rider driving patterns to a focus on potential station locations. The local and regional effect 

on roadways due to the Project would be analyzed more fully in the Tier 2 NEPA phase. However, in 

general, the change in driving patterns would potentially affect roadway LOS, particularly in places 

where roadways already experience some congested time periods. Using the highway LOS as a 

measure of regional traffic operations, many locations along I-75 and its intersections with I-85 and I-
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-14 September 2016

285 experience degraded LOS, as shown in Table 3-3 and Figures 3-1 and 3-2. US 411 and the 

Folsom Road section of I-75 have generally better LOS operations. Considering the length of 

corridor where degraded LOS is a concern, the East Corridor Alternative and I-75/Rome Corridor 

Alternative may have less overall impact on regional travel than the I-75 Corridor Alternative.

Locally, the Project would change travel patterns in the vicinity of proposed stations as people travel 

to and from the stations. Localized roadway improvements may be required to accommodate 

roadway impacts resulting from the Project. Such improvements would relate to managing 

circulation, accommodating added traffic volume, and considering safety of pedestrians and 

bicyclists. Stations have the potential to induce re-zoning and development in the area around

stations. For example, transit-oriented development (TOD), which increases the density of 

residential and commercial land uses, can change vehicular, transit, pedestrian and bicycle travel 

patterns. In coordination with local planning officials, GDOT and TDOT will examine each proposed

station location during the Tier 2 NEPA phase and develop improvements as warranted and 

reasonably feasible.

A large percentage of each Corridor Alternative would be within existing highway ROW. The 

approximate percentage that each Corridor Alternative would share existing highway ROW is shown 

in Table 3-4 and illustrated on Figure 3-4. Use of existing highway ROW is intended to minimize 

additional ROW needs and impacts on the natural and built environment. GDOT and TDOT 

anticipate that the Project would not change the permanent number of highway travel lanes on the 

affected highways. The proposed HSGT operations would be grade separated as reasonably 

feasible. During the Tier 2 NEPA phase, the analysis will determine if potential crossings of 

roadways would be necessary and will evaluate potential road closures and/or realignments. The 

Project Team will coordinate with local government agencies to ensure input and feedback on 

potential solutions. The analysis that will be conducted in the Tier 2 NEPA phase will be based on 

costs, engineering constraints, and potential environmental impacts of the grade separation to 

determine feasibility. At no point is the HSGT envisioned to cross roadways at-grade. GDOT and 

TDOT’s decision-making approach for roadway crossings would be guided by FRA’s 2009 HighwayRail Grade Crossing Guidelines for High Speed Passenger Rail. FRA’s guidelines focus on issues 

such as safety, warning systems and traffic controls, train controls, barriers, and pedestrians.

Table 3-4: Proportion of Corridor Alternative within Existing ROW

Corridor Alternative Approximate Percentage

I-75 76

East 31

I-75/Rome 53

During construction, the Project has the potential to temporarily affect roadway operations due to 

construction staging, access requirements, and other activities. These aspects would be examined 

in Tier 2 analysis.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-15 September 2016

Figure 3-4: Use of Existing Highway Corridors
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-16 September 2016

Effects on Existing Railroads

As shown on Figure 3-3, all corridor alternatives parallel the W&A Line and other rail alignments in 

the Chattanooga area and cross the W&A Line twice just south of Cartersville. Other potential effects 

would occur as follows:

 I-75 Corridor Alternative – Parallels W&A Line for short distances, one in Gordon County and 

one in Whitfield County; crosses the CSX Line in Bartow County and the W&A Line in Catoosa 

County;

 East Corridor Alternative – Parallels the CSX Line from when it departs from the I-75 corridor 

until it turns west just south of Chatsworth and the W&A Line in Catoosa County as it 

approaches the Tennessee border; crosses the CSX Line as it turns west and the H-Line in 

Whitfield County

 I-75/Rome Corridor Alternative – In the section that departs from the I-75 Corridor, parallels the 

H-Line between Rome and where it rejoins I-75; crosses both the CSX and W&A Lines in Bartow 

County.

The Project is not envisioned to share track with existing railroad freight service since railroads have 

a preference for distance between tracks used for freight and tracks used for passenger service. As 

such, GDOT and TDOT would avoid permanent and temporary Project-related effects on existing 

railroads where possible.

Effects on Existing Transit 

The Project would add an intercity HSGT transportation option that does not currently exist in the 

Project Area. The provision of HSGT service in a dedicated guideway would enable ground travelers 

currently using a bus or automobile to avoid roadway congestion. In cases where private automobile 

travel is the only transportation option today, the proposed HSGT service would substantially 

increase transportation options. The proposed HSGT service would provide direct, competitive 

connections to local and regional destinations within the Project Area, as well as to HJAIA and CMA 

airports, and transit and rail services beyond the Project Area. Estimated end-to-end Project travel 

times are listed below along with existing travel times by mode for reference:

 I-75 Corridor Alternative – 88 minutes

 East Corridor Alternative – 95 minutes

 I-75/Rome Corridor Alternative – 102 minutes

 Air – 120 minutes (airport gate to gate; includes wait time 60 minutes arrival prior to 

departure and airport gate to gate)

 Intercity bus – 125 to 185 minutes

 Automobile (on I-75) – 110 minutes (non-peak)

These data indicate that each Corridor Alternative would reduce ground travel time and be 

competitive with air travel time. The I-75 Corridor Alternative would have the shortest time (88 

minutes), followed by the East Corridor Alternative (95 minutes); the I-75/Rome Corridor Alternative 

would have the longest travel time (102 minutes). Travel time differences are largely a function of the 

length of each corridor. Beyond travel time, the nature of the Project as an HSGT service on 

dedicated guideway enables it to be operated on a predictable schedule. Reliability is a substantial 

benefit for travelers, particularly those making scheduled connections to other transportation 

services. 

Connectivity of the Project with existing transit services is an important need for the Project; potential 

linkages will be studied during the Tier 2 NEPA process. In this Tier 1 DEIS, the Project Team is 

proposing a Project connection to the MARTA heavy rail system for each Corridor Alternative at 

either the Five Points station or the Dome/GWCC/Phillips Arena/CNN station. In addition, the 

Corridor Alternatives would introduce new train stations that may affect localized and regional bus 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-17 September 2016

transit routes. Some bus routes may be changed to accommodate changes in traffic patterns 

resulting from the locations of stations. During construction, surface transit operations on roadways

in the Project Area could be delayed, which could affect existing bus services.

Effects on Local Parking

The need for vehicular parking will be assessed during Tier 2 NEPA analysis, based on the selected 

station locations, the associated community planned land use, and existing parking availability. 

Travel Time and Ridership

The effects of the Corridor Alternatives on the transportation system in the Project Area can be 

summarized by reviewing the mobility measures including travel time and forecast ridership. Table 

3-5 presents the ridership and both end-to-end and station-to-station travel times. The station areas 

listed in the table are representative of a typical station, and ridership is projected to these general 

locations in the travel demand model.

Table 3-5: Ridership and HSGT Travel Time

Corridor

Alternative

Daily 

Ridership 

(2040)

End to End Travel Time (minutes)

Station Area to Station Area Travel Time (minutes)

HJAIA/SC to Downtown ATLDowntown ATL to Cumberland / GalleriaCumberland / Galleria to Town CenterTown Center to CartersvilleCartersville to RomeRome to DaltonCartersville to DaltonCartersville to DaltonChatsworthDalton to CMADalton - Chatsworth to CMACMA to Downtown Chattanooga

I-75 11,725 88 11 11 9 15 NA NA 17 NA 14 NA 11

East 8,556 95 11 11 9 15 NA NA NA 20 NA 18 11

I-75/Rome 13,204 102 11 11 9 15 14 17 NA NA 14 NA 11

Source: AECOM. 2014. Ridership model developed for this Project, See Appendix D. 

The I-75 Corridor Alternative would have the shortest travel time and the second highest ridership. 

The East Corridor Alternative travel time would be longer than for I-75, but shorter than for I75/Rome, and it would have the lowest ridership. The I-75/Rome Corridor Alternative would have the 

longest travel time, but it would have the highest ridership.

3.3.5 Potential Mitigation

Operations

If a Corridor Alternative is selected, efforts will be made to avoid or minimize impacts on 

transportation facilities as the Project advances. A number of potential mitigation strategies will be 

considered to offset impacts. Strategies that would mitigate the Project’s impact on highways, local 

roads, transit operations, and parking vary depending on the nature of the impact. For example, near 

stations or where the selected Corridor Alternative crosses existing roadways on structures, physical 

improvements may need to be made to intersections or roadway cross-sections to facilitate access 

and safe circulation. 

Station, parking, and maintenance facility designs could include operational and geometric 

improvements that maintain, wherever reasonably feasible, traffic conditions at acceptable levels of 

service. In general, mitigation could include the realignment of local traffic patterns and the creation 

of additional parking. Examples of roadway improvements to facilitate station access include turn 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-18 September 2016

lanes at intersections, local roadway capacity improvements, traffic control measures, coordination 

with local transit operations, and improvements in pedestrian and bicycle access. Landscape and 

streetscape enhancements also could better integrate stations with adjacent land uses. 

Construction

The temporary construction effects to roadways and surface transit would be addressed by Best 

Management Practices during construction. 

It is anticipated that, to the extent possible, work would be staged during night-time, weekends, or 

off-peak hours to minimize service outages and disruptions to the traveling public. The contract 

specifications would require road closures and detours to be strictly coordinated so that traffic can 

take practical and short detour routes. Temporary closures and detours would be done in sequence 

as the project progresses geographically through a particular construction zone. During such 

closures and detours, the construction contractor would be required to post detours for traffic and 

implement other measures to ensure that traffic flow can be accommodated in an efficient manner 

as may be both practical and safe.

The Project Sponsors would also coordinate with local agencies regarding hauling of construction 

materials on public streets to identify acceptable routes and times of operation. Traffic would be 

managed by detailed traffic control plans. The contractor, with the Project Sponsors, would 

coordinate with potentially affected public services in planning traffic control measures. Construction 

activities that might substantially disrupt traffic would not likely be performed during peak travel 

periods to the maximum extent practicable. Access to all businesses and residences would be 

maintained.

Warning signs would be used as appropriate to provide notice of road hazards and other pertinent 

information to the traveling public. Signage and barricades would be used as part of the typical 

roadway construction traffic controls. Temporary traffic signal adjustments and/or temporary manual 

traffic control could be required when construction occurs at signalized intersections on adjacent 

arterials or roadways. The effectiveness of the traffic control measures would be monitored during 

construction and adjustments would be made, as necessary. The local news media would be notified 

in advance of road closures, detours, and other construction activities. Information would also be 

posted on the project website.

3.3.6 Subsequent Analysis

The Tier 2 NEPA process will entail more detailed planning and engineering to address connections 

to existing transportation systems, as well as potential effects on capacity requirements of 

transportation facilities affected by the Project. For example, the Tier 2 NEPA process will examine a 

connection to the MARTA heavy rail system that is proposed for each Corridor Alternative at the 

proposed Five Points station or the proposed Dome/GWCC/Phillips Arena/CNN station. The process 

will also include detailed planning and engineering to establish connections to local and regional bus 

systems since they are non-fixed guideway modes and can be dynamically altered over time based 

upon shifting demands and trip-making behaviors. These inputs are harder to anticipate but easier to 

adjust once station locations are determined. The planning and development of local and regional 

bus routes and schedules will also be completed by the owners of the bus services after the Tier 2 

NEPA process.

The effects and mitigation measures that could be taken to address the capacity requirements of 

local roadway, transit, and pedestrian and bicycle networks generated by stations and TOD will be 

undertaken in the Tier 2 NEPA process as well. A more in-depth discussion of the effects to, and 

resulting from, land use changes will be addressed in that process. The need for vehicular parking 

will also be assessed in the Tier 2 NEPA process, based on selected station locations and the 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-19 September 2016

associated community planned land use and existing parking availability. All stations would be 

designed to comply with the Americans with Disabilities Act (ADA) of 1990, as amended by the ADA 

Amendment of 2008. A full range of necessary transportation-related mitigation commitments will be 

developed in the Tier 2 NEPA analysis. 

In addition, when a Tier 1 Preferred Alternative is selected, more detailed analyses would be 

performed to analyze travel demand, which would include the development of an optimized HSGT 

operating timetable for the Preferred Alternative. The analysis would be an iterative process that

would address optimal frequency and time of day requirements by market, while also considering the 

cost required to provide the service. The analysis would have implications on the Project’s ridership, 

capital costs and operating costs. The timetable optimization process would be coordinated with 

other rail corridor initiatives within region. Additionally, depending on the amount of time that passes 

between the completion of this Tier 1 DEIS and additional analyses, updated travel market data, 

demographic data and forecasts may be required in the travel demand model. The update would 

include the latest Metropolitan Planning Organization (MPO) base year and future year highway

networks; the latest MPO, statewide, and national socio-economic data and forecasts; and the latest

air travel market data. The selected Preferred Alternative would also be subjected to the plan 

development processes of review and approvals by the States of Georgia and Tennessee, and the 

FRA.

3.4 Air Quality

This section describes the existing air quality of the Project Area and assesses the potential effect of 

the alternatives on air quality. Air quality would be a distinguishing factor among the alternatives in 

terms of reducing vehicular emissions by attracting ridership from other modes. However, there is no 

substantial difference among the alternatives. In addition, the technologies considered would both 

use electric power, which may come from coal-fired power generation plants. However, the source of 

the HSGT’s electric power is beyond the scope of a Tier 1 analysis and was not a consideration in 

the determination of potential air quality impacts.

3.4.1 Legal and Regulatory Context

The federal agency that develops and enforces the regulations that help govern air quality is the 

USEPA. The CAA, as amended in 1990, led the USEPA to establish National Ambient Air Quality 

Standards (NAAQS) for six criteria pollutants to protect the public from health hazards associated 

with air pollution. The six criteria air pollutants are: carbon monoxide (CO), ozone (O3), nitrogen 

dioxide (NO2), sulfur dioxide (SO2), particulate matter (PM10 and PM2.5), and lead (Pb). The sources 

of these pollutants, their effects on human health, and their concentrations in the atmosphere vary. 

Table 3-6 shows the NAAQS for each criteria pollutant. The states of Georgia and Tennessee have 

adopted these standards as the State Ambient Air Quality Standards. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-20 September 2016

Table 3-6: National Ambient Air Quality Standards (NAAQS) for Criteria Pollutants

Pollutant

[final rule cite]

Primary/ 

Secondary Averaging Time Level Form

Carbon Monoxide

[76 FR 54294, Aug 31, 

2011] 

primary

8-hour 9 ppm Not to be exceeded more 

1-hour 35 ppm than once per year

Lead

[73 FR 66964, Nov 12, 

2008] 

primary 

and 

secondary

Rolling 3 month 

average

0.15 

μg/m3 Not to be exceeded

Nitrogen Dioxide

[75 FR 6474, Feb 9, 2010]

[61 FR 52852, Oct 8, 1996]

primary 1-hour 100 ppb 98th percentile, averaged 

over 3 years

primary 

and

secondary

Annual 53 ppb Annual Mean

Ozone

[73 FR 16436, Mar 27, 

2008]

primary 

and 

secondary

8-hour 0.075 

ppm 

Annual fourth-highest daily 

maximum 8-hr 

concentration, averaged 

over 3 years

Particle 

Pollution

Dec 14, 2012

PM2.5

primary Annual 12 μg/m3 annual mean, averaged 

over 3 years

secondary Annual 15 μg/m3 annual mean, averaged 

over 3 years

primary 

and 

secondary

24-hour 35 μg/m3 98th percentile, averaged 

over 3 years

PM10

primary 

and

secondary

24-hour 150 μg/m3

Not to be exceeded more 

than once per year on 

average over 3 years

Sulfur Dioxide

[75 FR 35520, Jun 22, 

2010]

[38 FR 25678, Sept 14, 

1973]

primary 1-hour 75 ppb

99th percentile of 1-hour 

daily maximum 

concentrations, averaged 

over 3 years

secondary 3-hour 0.5 ppm Not to be exceeded more 

than once per

μg/m3= micrograms per cubic meter ppm = parts per million

Source: USEPA. National Ambient Air Quality Standards, December 14, 2012 http://www.epa.gov/air/criteria.html

The USEPA delegates authority to the Georgia Department of Natural Resources Environmental 

Protection Division (GDNR EPD), Air Protection Branch for monitoring and enforcing air quality 

regulations in the State of Georgia. Similarly, the Department of Environment and Conservation, Air 

Pollution Control (APC) is responsible for monitoring and enforcing air quality regulations in the State

of Tennessee. The Georgia State Implementation Plan (SIP) (USEPA 2005) and the Tennessee SIP 

(USEPA 2006), developed in accordance with the CAA, contain the major requirements with respect 

to air quality. Under the authority of the CAA, Federal entities are prohibited from taking actions in 

nonattainment or maintenance areas that do not conform to the SIP for the attainment and 

maintenance of the NAAQS. Conformity analyses ensure that Federal activities do not interfere with 

the budgets in the SIPs, that Federal activities do not cause or contribute to new violations, and that 

States achieve overall attainment and maintenance of the NAAQS. FRA actions are covered under 

General Conformity (58 FR 63214).

A project conforms to the SIP if it is included in a conforming metropolitan transportation plan. The 

HSGT Project is included in the Chattanooga - Hamilton County / North Georgia Regional Planning 

Agency (CHRPA) Chattanooga Urban Area Transportation Improvement Program and the 2035 

Long Range Transportation Plan, Creating a Multi-modal Network (CHRPA 2010). The Project is not 

included in the Atlanta Regional Commission (ARC) PLAN 2040 RTP (2010); however, high-speed 

rail studies are included in GDOT’s fiscal year (FY) 2010-2014 State Transportation Improvement 

Program (STIP) (2014). The U.S. DOT has concurred in the conformity determination for the CHRPA 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-21 September 2016

plans; however, since the Project is not included in the ARC, Greater Dalton MPO, or Rome/Floyd 

CPC plans, it does not conform to the SIP and the Project must be approved by the U.S. DOT.

3.4.2 Methodology

A qualitative air quality analysis was performed for the Project. Data on existing air quality conditions 

were obtained from the GDNR EPD and Tennessee APC. Future planning phases of the Project will 

include a conformity determination and a hot spot analyses at the points in time and places where 

congestion is expected to be greatest or in areas of sensitive receptors.

3.4.3 Affected Environment

According to the GDNR EPD, Air Protection Branch, the following counties within the Georgia 

portion of the Project Area were designated as a Non-Attainment Area for 8-hour ozone standard 

and the PM2.5 standard (2014):

 Clayton, GA

 Fulton, GA

 Cobb, GA

 Paulding, GA

 Douglas, GA

 Cherokee, GA

 Bartow, GA

The 1-hour ozone standard was revoked for the 13-County Atlanta metro area (part of the 20-County 

area) as of June 15, 2005. Hamilton County, Tennessee is designated as a Non-Attainment Area for 

the 1997 PM2.5 standard. The Atlanta and Chattanooga areas both are in attainment for all other 

criteria pollutants. Table 3-7 shows monitored ambient air quality in the Project are for 2012 and 

2013. 

Table 3-7: Monitored Ambient Air Quality in the Project Area

Pollutant Monitor Location County Averaging 

Period

Concentrations

2012 2013

Nitrogen Dioxide 

(NO2)

King Farm, 160 Ralph King Path, Rockmart, GA Polk 1 Hour 24 27

Ozone (O3)

GA National Guard, 1901 McCollum Parkway, 

Kennesaw, GA Cobb 8 Hours 0.087

3

0.073

0

935 East Confederate Ave., Atlanta, GA. Fulton 8 Hours 0.101

10

0.096

2

Fort Mountain, State Hwy 52, Cohutta Overlook, 

Chatsworth, GA Murray 8 Hours 0.0761

0.068

0

Soddy Daisy H.S. 00618 Sequoyah Rd Soddy 

Daisy, TN Hamilton 8 Hours 0.085

5

0.077

0

6200 Bonny Oaks Drive Eastside Utility Filter 

Plant Chattanooga, TN Hamilton 8 Hours 0.090

4

0.078

0

Particulate Matter 

(PM2.5)

GA National Guard, 1901 McCollum Parkway, 

Kennesaw, GA Cobb 24 Hours 26.0 23.5

Coosa Elem. School, Hwy.20, Rome, GA Floyd 24 Hours 31.9 22.7

Fire Station #8, 1711 Marietta Blvd, Atlanta, GA Fulton 24 Hours 21.7 23.5

King Farm, 160 Ralph King Path, Rockmart, GA Paulding 24 Hours 17.9 23

601 Maple St, Lot#6, Rossville GA Walker 24 Hours 23.8 27.5

1517 Tombras Avenue, East Ridge, TN Hamilton 24 Hours 23.0 24.1

Soddy Daisy H.S. 00618 Sequoyah Rd Soddy 

Daisy, TN Hamilton 24 Hours 23.9 19.7

Riverside Substation 911 Siskin Dr, 

Chattanooga, TN Monitor 1 Hamilton 24 Hours 20.2 19.8

Riverside Substation 911 Siskin Dr, 

Chattanooga, TN Monitor 2 Hamilton 24 Hours 19.4 19.5

Bold = Number of exceedances

Source: USEPA. 2014. http://www.epa.gov/airdata/ad_rep_mon.html
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-22 September 2016

3.4.4 Environmental Consequences

3.4.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. The air quality pollutant 

concentrations related to auto, bus, and air could worsen under with the No-Build Alternative 

compared to the Corridor Alternatives, primarily due to emissions from heavier volumes of vehicular 

traffic in the future, though some emissions could be offset by increased use of more fuel efficient

cars. In addition, construction of the projects under the No-Build Alternative could also have 

temporary air quality impacts.

3.4.4.2 Corridor Alternatives

Criteria air quality pollutants (defined in Section 3.4.1) can cause serious health effects. According 

to the USEPA, exposure to the pollutants could lead to variety of health problems, including heart or 

lung disease, heart attacks, arrhythmia, asthma, decreased lung function, and respiratory issues. 

Regardless of the HSGT technology selected, the Project Team does not anticipate the Corridor 

Alternatives to cause or contribute to a new violation of any NAAQS, increase the frequency or 

severity of any existing violations, or delay timely attainment of any NAAQS. In fact, all Corridor 

Alternatives could result in a net reduction of burdens of criteria pollutants in the Project Area, which 

wouldhave positive long-term health benefits for the region. The difference between Maglev and 

steel-wheel high-speed ground transportation will be determined in the Tier 2 NEPA phase. Each 

Corridor Alternative has the potential to positively affect regional air quality by attracting riders to the 

proposed HSGT service from other modes, particularly the widely-used automobile. The I-75/Rome 

Alternative has the highest potential to attract riders from other modes to the proposed HSGT 

service and, thereby reduce vehicular emissions. This finding is based solely on the alternative 

having the highest ridership. Reduced travel by single occupancy vehicle could directly reduce 

combustion engine emissions, thereby having a possible beneficial effect on regional air quality 

compared to the No-Build Alternative. In addition, since the proposed service would operate in a 

sealed corridor with no at-grade crossings traffic emissions would not increase due to idling vehicles. 

Construction activities can result in short-term, localized effects on ambient air quality and generate 

a temporary increase in Mobile Source Air Toxics (MSAT) emissions. These potential effects include 

direct emissions from construction equipment and trucks, increased emissions from motor vehicles 

on the streets due to disruption of traffic flow, and fugitive dust emissions. Emissions from Project

related construction equipment and trucks are expected to be much less than the total emissions 

from other industrial and transportation sources in the region, and therefore, are not expected to 

cause a violation of the NAAQS. Fugitive dust emissions could occur during demolition, ground 

excavation, material handling and storage, movement of equipment at the site, and transport of 

material to and from the site. 

3.4.5 Potential Mitigation

Operations

Since the Corridor Alternatives are not anticipated to cause or contribute to any new violation of the 

NAAQS in Tennessee, mitigation measures would not be required for operations. In Georgia, an 

applicability analysis would have to be performed to determine if a general conformity analysis would 

be required because the project is not included in the ARC’s PLAN 2040 RTP (2010). 

Construction

Temporary construction effects are anticipated. The Project would adhere to the GDNR EPD 2010 

Fugitive Dust regulation 391-3-1-02(2)(n) and the APC Regulation for Fugitive Dust (Chapter 1200-
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-23 September 2016

3-8). Project-level assessments that render a decision to pursue construction emission mitigation 

would benefit from a number of technologies and operational practices that should help lower shortterm MSATs. In addition, SAFETEA-LU (Public Law 109-59, August 10, 2005) has emphasized a 

host of diesel retrofit technologies in the law’s Congestion Mitigation and Air Quality Improvement 

Program (CMAQ) program provisions - technologies that are designed to lessen a number of 

MSATs. The USEPA has listed a number of approved diesel retrofit technologies; many of these can 

be deployed as emissions mitigation measures for equipment used in construction. 

3.4.6 Subsequent Analysis

Subsequent analysis will include a detailed air quality assessment on the Preferred Alternative and 

the station and maintenance facilities locations are finalized. The analysis will evaluate Project’s 

impact on motor vehicle emissions due to local traffic to and from stations and of locomotives and 

other sources operating in rail yards. Potential construction impacts also will be analyzed. If the 

Project is not included in the Georgia SIP, an applicability analysis will be performed to determine if 

a general conformity analysis is required. A conformity determination will occur with subsequent 

phases of the HSGT Project.

3.5 Noise and Vibration

This section provides an overview of the potential noise and vibration effects of the Project.

3.5.1 Legal and Regulatory Context

FRA’s guidelines published in High-Speed Ground Transportation Noise and Vibration Impact

Assessment (FRA 2012) form the basis for determining the potential noise and vibration effects 

associated with high-speed and conventional-speed rail Maglev transportation with train speeds of 

90 to 250 miles per hour.

3.5.2 Methodology

Noise

The Project Team conducted a preliminary noise evaluation according to the FRA manual’s 

Screening Procedure, which is the appropriate analysis level for project corridors where the 

technology and alignments have not been selected, and identifies noise-sensitive land uses. It is 

based on very general assumptions. It indicates whether any noise-sensitive land uses are close 

enough to the Corridor Alternatives for noise impacts to be possible. The Screening Procedure

focuses on the potential noise impacts from high-speed trains passing near noise-sensitive land 

uses. Noise from ancillary sources, such as electrical substations, maintenance facilities, and 

increased roadway traffic near HSGT stations, is not assessed at this stage due to lack of detail and 

placement of these potential noise sources. The extent and severity of impact will be determined by 

a detailed noise assessment, as the project definition is refined in the Tier 2 NEPA phase, when 

specific alignments and associated HSGT infrastructure are evaluated.

For each of the Corridor Alternatives, the acreages of sensitive land uses were calculated within 

FRA-recommended screening distances for noise and vibration impacts. The types of land uses that 

are sensitive to noise impacts are listed in Table 3-8.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-24 September 2016

Table 3-8: FRA Noise-Sensitive Land Use Categories and Metrics for High-Speed Train Noise 

Land Use 

Category

Noise Metric 

(dBA) Description of Land Use Category

1 Outdoor Leq(h)*

Tracts of land where quiet is an essential element in their intended purpose. This 

category includes lands set aside for serenity and quiet, and such land uses as 

outdoor amphitheaters and concert pavilions, as well as national historic 

landmarks with significant outdoor use. Also included are recording studios and 

concert halls. 

2 Outdoor Ldn

Residences and buildings where people normally sleep. This category includes 

homes, hospitals, and hotels where a nighttime sensitivity to noise is assumed to 

be of utmost importance.

3 Outdoor Leq(h)*

Institutional land uses with primarily daytime and evening use. This category 

includes schools, libraries, theaters, and churches, where it is important to avoid 

interference with such activities as speech, meditation, and concentration on 

reading material. Places for meditation or study associated with cemeteries, 

monuments, and museums can also be considered to be in this category.

Certain historical sites, parks, campgrounds, and recreational facilities area also 

included.

*Leq for the noisiest hour of transit-related activity during hours of noise sensitivity

Source: FRA. 2012. High-Speed Ground Transportation Noise and Vibration Impact Assessment

For this screening, the acreages of each of the following land use types were determined:

 Residential

 Public/Institutional

 Parks, Recreation, and Conservation Areas

Although the Corridor Alternatives would use either steel-wheeled or Maglev technology, the 

screening distance for steel-wheel technology was applied in order to cover the widest area of 

analysis and potential impact. A screening distance of 1,100 feet from the corridor centerline was 

used for rural/suburban areas, while 600 feet from corridor centerline was used for suburban/urban 

areas based on FRA manual guidance for steel-wheel HSGT systems within highway environments.

For the Atlanta-Chattanooga HSGT analysis, the suburban/urban screening distance (600 feet) was 

applied for the corridor in Clayton, Fulton, Cobb, and Hamilton Counties. The suburban/rural 

distance (1,100 feet) was used for Cherokee, Bartow, Floyd, Gordon, Murray, Whitfield, and Catoosa 

Counties.

Vibration

As with the noise analysis, a vibration screening procedure was conducted to determine whether 

vibration-sensitive land uses are close enough to the Corridor Alternative for potential ground-borne 

vibration impacts to be possible. The screening procedure does not require any specific knowledge 

about the vibration characteristics of the system or the geology of the area. More detailed vibration 

analysis will be done in the Tier 2 NEPA phase if any sensitive land uses exist within the screening 

distances. Table 3-9 shows the land uses that are sensitive to ground borne vibration impacts.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-25 September 2016

Table 3-9: FRA Ground Borne Vibration Impact Criteria 

The screening distance is determined by the proposed train speed, frequency and land use type.

This vibration screening analysis uses the widest screening distance for HSGT, which is 275 feet.

This screening distance was applied to each of the corridor alternatives to determine acreage of 

residential and public/institutional land areas within the screening buffer.

3.5.3 Affected Environment

The Project Area contains noise- and vibration-sensitive land uses, which include residences, parks, 

schools, and institutional land uses where people spend time. The Project Area also includes 

urbanized areas where traffic and other activities already affect ambient noise, as well as agricultural 

and rural land where ambient noise would currently measure very low. 

Table 3-10 shows the acreage of noise-sensitive land uses within the applied screening distance for 

each of the corridor alternatives. The I-75/Rome Corridor Alternative has the most noise-sensitive 

land acreage within its screening area, while I-75 has the least. This may be attributable to the fact 

that a greater length of the I-75 Corridor Alternative is adjacent to the interstate highway system, 

whereas the other two alternatives deviate from the interstate and travel along U.S. highways (which 

tend to have more development located closer to the roadway than interstate highways). Most of the 

noise-sensitive land uses along the three corridors is residential.

Table 3-10: Noise-Sensitive Land Use Acreage Within Screening Distance by Alternative

Land Use Type Corridor Alternative

I-75 East I-75/Rome

Parks/Recreation Areas/Conservancy Areas 805 689 878 

Public/Institutional 542 915 851

Residential 4,567 5916 6,696

Total Area of Noise-Sensitive Land Uses 5,914 7,520 8,425

Sources: Atlanta Regional Commission: LandPro 2010; Northwest Georgia Regional Commission: Floyd County existing land 

use 2009, Gordon County existing land use 2007, Murray County existing land use 2005, Whitfield County existing land use 2010,

Catoosa County existing land use 2010; Chattanooga-Hamilton County Regional Planning Agency: Hamilton County existing land 

use 2010.

Table 3-11 shows the acreage of vibration-sensitive land uses within the screening area of each 

corridor alternative, which is 275 feet from the centerline. The East Corridor Alternative has the most 

Land Use Category

Ground-Borne Vibration 

Impact Criteria

(VdB relative to 1 micro 

inch/second)

Frequent 

Eventsa

Infrequent Eventsb

Category 1: Buildings where vibration would interfere with interior operations 65 VdBc

65 VdBc

Category 2: Residences and buildings where people normally sleep 72 VdB 80 VdB

Category 3: Institutional land uses with primarily daytime use 75 VdB 83 VdB

Source: FRA 2012.

a

Frequent Events is defined as more than 70 vibration events per day.

b

Infrequent Events is defined as fewer than 70 vibration events per day.

c

This criterion limit is based on levels that are acceptable for most moderately sensitive equipment, such as optical microscopes. 

Vibration-sensitive manufacturing or research will require detailed evaluation to define the acceptable vibration levels. Ensuring 

lower vibration levels in a building often requires special design of the heating, ventilating and air conditioning systems, and 

stiffened floors.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-26 September 2016

vibration-sensitive land uses within the screening distance, followed by the I-75/Rome Corridor 

Alternative and the I-75 Corridor Alternative. Similar to the noise analysis, the table shows that 

residential land uses comprise the majority of the vibration-sensitive areas along the project 

corridors.

Table 3-11: Vibration-Sensitive Land Use Acreage Within Screen Distance by Alternative

Land Use Type Corridor Alternative

I-75 East I-75/Rome

Public/Institutional 146 291 231

Residential 746 1,404 1,140

Total Area of Vibration-Sensitive Land Uses 892 1,695 1,371

Sources: Atlanta Regional Commission: LandPro 2010; Northwest Georgia Regional Commission: Floyd County existing land 

use 2009, Gordon County existing land use 2007, Murray County existing land use 2005, Whitfield County existing land use 2010,

Catoosa County existing land use 2010; Chattanooga-Hamilton County Regional Planning Agency: Hamilton County existing land 

use 2010.

3.5.4 Environmental Consequences

3.5.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. The No-Build Alternative 

projects would increase capacity and expand service in selected portions of the Project Area 

transportation network. However, no enhanced intercity passenger HSGT mobility would be provided 

in the Project Area. In general, the noise and vibration levels along the major highway corridors are 

likely to increase, primarily due to heavier volumes of vehicular traffic in the No-Build Alternative. As 

the geographic scope and nature of the No-Build Alternative projects is limited, the potential effects 

of the projects are likely to be contained to the area in which the individual projects would be 

constructed.

3.5.4.2 Corridor Alternatives

The screening shows that all three corridors have noise- and vibration-sensitive land uses that could 

be affected by HSGT operations. As described above, the I-75/Rome and East Corridor Alternatives 

have more acres of noise- and vibration-sensitive land uses located along the corridor than in the I75 Corridor. This may be attributable to the fact that a greater length of the I-75 Corridor Alternative 

is adjacent to the interstate highway system. The I-75 and I-75/Rome Corridors also pass through 

more developed areas presenting a higher likelihood of noise and vibration effects. However, 

because the proposed service would be completely grade separated, impacts related to horn blows 

at grade crossings would not occur. Because steel-wheel vehicles produce greater noise and 

vibration than Maglev, the noise and vibration screening distances were based on steel-wheel 

technology (FRA 2012). If Maglev technology is chosen, there would likely be fewer noise and 

vibration impacts. The detailed analysis for noise and vibration performed during Tier 2 NEPA would 

also quantify the differences in impact between the two technologies.

Typical construction activities may include, but are not limited to track-laying and relocation, station 

construction and construction of parking facilities. Noise and vibration levels from construction 

activities for the Corridor Alternatives, although temporary, could create a nuisance condition at 

nearby sensitive receivers. The potential for exposure to construction-related noise and vibration 

levels varies depending on the types of construction activity and the types of equipment used for 

each stage of work. 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-27 September 2016

3.5.5 Potential Mitigation

Operations

Noise

When a detailed noise analysis is conducted during the Tier 2 NEPA phase, potential noise effects 

will be quantified, strategies to avoid or minimize noise effects will be examined for feasibility and 

incorporated into the design, and strategies to mitigate the remaining unavoidable effects would be 

examined. Noise control and mitigation strategies that could be examined include:

 Installation of noise barriers - Depending on the height and location relative to the tracks, 

noise barriers can achieve between 5 and 15 dB (decibel) of noise reduction. The primary 

requirements for an effective noise barrier are that the barrier must (1) be high enough and long 

enough to break the line-of-sight between the sound source and the receiver, (2) be of an 

impervious material with a minimum surface density of 4 pounds per square foot, and (3) not 

have any gaps or holes between the panels or at the bottom. Because many materials meet 

these requirements, aesthetics, durability, cost, and maintenance considerations usually 

determine the selection of materials for noise barriers. Depending on the situation, noise barriers 

can become visually intrusive, which would have to be evaluated during the Tier 2 NEPA phase. 

Coordination with affected communities would be needed to determine the appropriateness of 

the material. 

 Building sound insulation - Sound insulation of residences and institutional buildings to 

improve the outdoor-to-indoor noise reduction is a mitigation measure that can be provided when 

the use of noise barriers cannot provide a feasible level (5 to 7 dB) of noise reduction. Although 

this approach has no effect on noise in exterior areas, it can provide noise reduction for 

residential/institutional interiors, which can be especially important where noise barriers are not 

feasible or desirable and for buildings where indoor sensitivity is of most concern. Sound 

insulation will be further evaluated in Tier 2 based on noise impact analysis of the refined 

alignment and train technology, and in accordance with applicable GDOT, TDOT, and FRA 

policies on noise abatement.

 Source Treatments – Source treatments include measures to reduce noise through the train 

vehicles and rails, due to materials and quality of construction of wheels, the vehicle body type, 

propulsion and ventilation systems used, and materials and quality of construction of the vehicle 

guideway support. In the procurement of an HSGT vehicle technology, the proposed project can 

set performance limits for noise levels in order to reduce community noise effects throughout the 

corridor. The types of technology available and cost considerations will inform the potential to

reduce the noise throughout the corridor through various vehicle and guideway design 

considerations; therefore potential source treatments will be further evaluated in Tier 2.

Vibration

Control of ground-borne vibration that exceeds the FRA effect criteria could be achieved using a 

resilient track design. Depending on the track design, there are different methods to control vibration. 

For steel-wheel slab track, resilient direct fixation fasteners could be used, and for ballast and tie 

track either shredded tire aggregate or rubber ballast mats. For Maglev, various damping control 

measures directed towards the secondary suspension can be applied.

Construction

During the construction phase, noise and vibration control measures may be required to ensure 

compliance with all federal, state, and local guidelines and noise limits. For example, noise 

specifications could require contractors to use properly maintained and operated equipment, 

including the use of exhaust mufflers according to the equipment manufacturer's specifications. 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-28 September 2016

Additional noise control measures could be incorporated into the construction specification 

documents as determined to be necessary during final design. Several areas of potential noise 

control during construction include:

 Temporary noise barriers erected between noisy activities and noise-sensitive receptors;

 Use of sonic/vibratory pile-drivers rather than effect pile-driving near noise-sensitive receptors; 

 Restrictions on hours of construction work to daytime hours, and adherence to any applicable 

county/municipal noise ordinances; and

 Rerouting construction traffic along roadways that minimize noise effects at nearby noise 

sensitive receivers.

Additionally, vibration specifications could require contractors to use alternative construction 

methods and equipment, including the use of vibratory pile drivers rather than effect pile drivers. 

Vibration control measures could be incorporated into the construction specification documents as 

determined to be necessary during final design. The areas for potential vibration control during 

construction include:

 Utilizing alternative construction methods that avoid pile driving near vibration-sensitive 

receivers, such as residences, schools and hospitals;

 Whenever possible, use of drilled piles or sonic/vibratory pile drivers to reduce excessive 

vibration;

 Rerouting truck traffic away from vibration-sensitive receptors; and

 Requiring contractors to use Best Available Control Technologies (BACT) to limit excessive 

vibration.

3.5.6 Subsequent Analysis

A detailed noise and vibration analysis will be conducted during the Tier 2 NEPA process when a

Corridor Alternative is selected. In the Tier 2 NEPA process, the alignment within the preferred 

Corridor Alternative will be configured, a technology (steel-wheel or Maglev) will be chosen, exact 

station and maintenance facility locations will be identified, as well as other necessary infrastructure

to accommodate the proposed service. The analysis will take into consideration the noise and 

vibration levels from new HSGT activity along the corridor, including the number of number of 

locomotives on each train or Maglev, the speed of each, and hours of operation, as well as potential 

effects related to electrical substations, HSGT passenger stations, and maintenance facility 

operations. Potential noise and vibration effects will be quantified, strategies to avoid or minimize the 

potential effects will be examined for feasibility and incorporated into the design, and strategies to 

mitigate the remaining effects will be identified. Noise and vibration control measures will comply

with all applicable federal, state, and local construction regulations.

3.6 Socioeconomics and Environmental Justice

This section describes the socioeconomic conditions and environmental justice (EJ) populations 

within the Project Area. It also presents the potential effects of the Project on these conditions and 

populations. As the proposed station locations vary among the Corridor Alternatives, distinguishing 

factors potentially include the specific populations, employment areas and EJ populations in 

proximity to proposed station locations. In addition, the ratio of EJ populations to non-EJ in each 

Corridor Alternative varies. This section also broadly describes the potential effects to 

neighborhoods, community resources, and community cohesion; however, detailed impacts such as 

property acquisitions or displacements will be evaluated in the Tier 2 NEPA phase. Effects on 

children, as per Executive Order 13045 – Protection of Children From Environmental Health Risks 

and Safety Risks, would also be further analyzed in the Tier 2 NEPA phase.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-29 September 2016

3.6.1 Legal and Regulatory Context 

The Council on Environmental Quality’s (CEQ’s) Regulations for implementing the provision of 

NEPA (40 CFR 1500-1508) state that the "human environment shall be interpreted comprehensively 

to include the natural and physical environment and the relationship of people with that 

environment." The following Executive Order, USDOT Order and guidance documents pertain to the 

assessment of effects on EJ populations. 

 Executive Order 12898 – Federal Actions to Address Environmental Justice in Minority 

and Low-Income Populations (1994) – requires all federal agencies to “develop an agencywide environmental justice strategy that identifies and addresses disproportionately high and 

adverse human health or environmental effects of its programs, policies, and activities on 

minority populations and low-income populations.” 

 U.S. DOT Order 5610.2 (a) – Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations (1997) and Final DOT Environmental Justice 

Order (2012) – requires planning and programming activities that have the potential to have a 

disproportionately high and adverse effect on human health or the environment to include explicit 

consideration of the effects on minority populations and low-income populations. 

 Environmental Justice: Guidance Under the National Environmental Policy Act (1997),

prepared by the CEQ, provides guidance for conducting environmental justice analysis under 

NEPA including the suggested elements for public involvement and outreach, development of 

the environmental justice analysis methodologies, environmental justice definitions, 

environmental justice criteria, and environmental resource evaluation criteria for the 

determination of disproportionately high and adverse human health and environmental effects. 

The following Executive Order pertains to the assessment of effects on children:

 Executive Order 13045 – Protection of Children From Environmental Health Risks and 

Safety Risks (1997) – requires all federal agencies to “make it a high priority to identify and 

assess environmental health risks and safety risks that may disproportionately affect children; 

and...ensure that is policies, programs, activities, and standards address disproportionate risks 

to children that result from environmental health risks or safety risks.” 

3.6.2 Methodology

3.6.2.1 Socioeconomics

The defined study area for population access to the Project consists of a 10-mile radius around each 

proposed station location.

11 A 5-mile study area radius around each of the proposed station locations 

will be used to assess access to employment12. The purpose for measuring population and 

employment access is to provide a high-level estimation of each Corridor Alternative’s ability to 

serve and be located in proximity to areas of greater relative population and employment 

concentrations. The information and data presented in this section were obtained from the U.S. 

Census 1990, 2000, and 2000 data, and the American Community Survey 2008-2012 Update. 

 

11 The use of a 10-mile radius was selected as an estimation of the alternatives’ relative ability to serve areas having larger 

population centers.

12 A 5-mile radius was applied to employment access due to the lack of access to personal vehicles at the destination trip end. At 

the destination stations, the mobility options would include, pedestrian facilities, transit, and for-hire vehicles. There is no industry 

standard, but the methodology uses a planning assumption that 5 miles is the maximum distance people are willing to travel to work 

without a personal vehicle after arriving at a destination via HSGT.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-30 September 2016

3.6.2.2 Environmental Justice

The EJ analysis is based on identifying the presence of minority and low income populations within 

the defined study area. Minority populations include persons who are American Indian and Alaska 

Native, Asian, black or African American, Hispanic or Latino, Native Hawaiian, and other Pacific 

Islander. Low-income populations are defined as persons whose household income is at or below 

the U.S. Department of Health and Human Services poverty guidelines. The study area for the EJ

analysis is 1,000 feet wide centered on each corridor alternative. This 1,000-foot width is intended to

encompass and account for the improvements that would be associated with the alternative 

including infrastructure improvements (such as embankments, aerial structures, track 

improvements), ancillary facilities (such as stations, substations, yards, and parking structures), or 

service changes.

Minority populations were identified using U.S. Census Bureau Census 2010 tract level data for race 

and ethnicity. Low-income populations were identified using the U.S. Census American Community 

Survey 5-Year Estimates (2008-2012) tract level data for persons living below the poverty level. The 

classification of census tracts was based on criteria provided in the CEQ’s 1997 guidance on 

environmental justice analysis in NEPA documents. Based on this guidance, a tract in this study was 

categorized as having a high concentration of either minority or low-income population if:

 At least 50 percent of the population in the census tract is minority or low income; or

 The minority or low-income population in the tract is “meaningfully greater” than the average of 

the minority or low income population in the county in which the tract is located. 

For this Tier 1 DEIS, a census tract meets the “meaningfully greater” threshold if the percentage of 

minority or low-income residents is 50 percent, or higher than the percentage in the corresponding 

county.

3.6.3 Affected Environment 

3.6.3.1 Socioeconomics

The socioeconomic factors included in this section are population and employment and are 

presented in the following sections.

Population 

Table 3-12 shows the populations and population growth for each Project Area county between 

1990 and 2012. On the south end, the counties with the largest populations are Fulton and Cobb in 

the Atlanta metropolitan area, while at the north end Hamilton County had the greatest population 

growth. The counties with the highest growth between 2000 and 2012 were Paulding (74 percent)

and Cherokee (52 percent). Within the Project Area, population grew by 56 percent between 2000 

and 2012. The larger population densities are in the south and north ends of the Project Area, near 

Atlanta and Chattanooga as depicted in Figure 3-5. 

According to the ARC, the population of metropolitan Atlanta is projected to increase from 5.3 million 

persons (2010) to 8.3 million persons by the year 2040, a 57 percent increase (ARC 2009). The 

Chattanooga and Dalton regions also are experiencing growth. In Tennessee, Hamilton County, has 

experienced a faster than expected rate of population growth, having a population of 337,023, which 

already surpasses the most recent 2009 population forecast of 329,365 for the year 2030. 

Employment

Table 3-13 shows employment growth from 2000 to 2012 by county. Employment density for the 

Corridor Alternatives is depicted in Figure 3-6. The Atlanta metropolitan area is the economic engine 

of Georgia, representing two thirds of the state’s economy. Between 2000 and 2012, Paulding, 

Cherokee, and Bartow counties saw the highest growth in employment at 61 percent, 41 percent, 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-31 September 2016

and 88 percent, respectively. In the Project Area, employment grew by 13 percent between 2000 

and 2012. 

According to the ARC, employment in the metropolitan Atlanta is projected to increase from 2.2 

million persons (2010) to 3.7 million persons by the year 2040, a 68 percent increase (ARC 2009). 

No employment projections for Hamilton County were available at the time of writing.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-32 September 2016

Table 3-12: Overall Project Area Population Growth by County 2000-2012

County 1990 2000 2012

% 

Change 

1990-

2000

%

Change 

2000-

2012

% 

Change 

1990-

2012

Bartow, GA 55,915 76,019 99,872 36 31 79

Catoosa, GA 42,464 53,282 64,226 25 21 51

Chattooga, GA 22,242 25,470 25,905 15 2 16

Cherokee, GA 90,204 141,903 215,014 57 52 138

Clayton, GA 182,052 236,517 262,066 30 11 44

Cobb, GA 447,745 607,751 691,820 36 14 55

Douglas, GA 71,120 92,174 132,124 30 43 86

Floyd, GA 81,251 90,565 96,204 11 6 18

Fulton, GA 648,776 816,006 929,535 26 14 43

Gordon, GA 35,067 44,104 55,192 26 25 57

Murray, GA 26,147 36,506 39,635 40 9 52

Paulding, GA 41,611 81,678 141,846 96 74 241

Polk, GA 33,815 38,127 41,350 13 8 22

Walker, GA 58,340 61,053 68,463 5 12 17

Whitfield, GA 72,462 83,525 102,152 15 22 41

Hamilton. TN 211,000 307,896 337,023 46 9 60

Total Project Area 2,120,211 2,792,576 3,302,427 32 18 56

Georgia Total 6,478,216 8,186,453 9,714,569 26 19 50

Tennessee Total 4,877,185 5,689,283 6,353,226 17 12 30

Source: US Census Bureau, Census 1990, Census 2000, and American Community Survey 5-Year Estimates (2008-2012).

Table 3-13: Project Area Employment Growth 1990 to 2012

County 1990 2000 2012 % Change 

1990-2000

% Change 

2000-2012

% Change 

1990-2012

Bartow, GA 13,875 22,874 42,991 64.9 87.9 209.8

Catoosa, GA 20,146 27,154 29,467 34.8 8.5 46.3

Chattooga, GA 9,868 10,722 9,487 8.7 -11.5 -3.9

Cherokee, GA 48,237 75,316 105,797 56.1 40.5 119.3

Clayton, GA 96,580 114,468 114,093 18.5 -0.3 18.1

Cobb, GA 253,096 329,136 353,496 30.0 7.4 39.7

Douglas, GA 37,431 46,944 59,497 25.4 26.7 59.0

Floyd, GA 38,308 40,403 39,587 5.5 -2.0 3.3

Fulton, GA 320,149 392,627 447,421 22.6 14.0 39.8

Gordon, GA 17,439 22,451 23,399 28.7 4.2 34.2

Murray, GA 13,247 17,802 15,499 34.4 -12.9 17.0

Paulding, GA 20,732 41,472 66,571 100.0 60.5 221.1

Polk, GA 14,385 15,904 16,213 10.6 1.9 12.7

Walker, GA 26,571 27,753 27,652 4.4 -0.4 4.1

Whitfield, GA 37,932 39,593 44,421 4.4 12.2 17.1

Hamilton. TN 134,440 149,166 158,569 11.0 6.3 17.9

Total Project Area 1,104,426 1,375,785 1,556,172 24.6 13.1 40.9

Georgia Total 3,090,276 3,839,756 4,277,991 24.3 11.4 38.4

Tennessee Total 2,250,842 2,651,638 2,815,491 17.8 6.2 25.1

Source: US Census Bureau, Census 1990, Census 2000, and American Community Survey 5-Year Estimates (2008-2012).
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-33 September 2016

Figure 3-5: Population Density in the Project Area

Source: US Census Bureau, American Community Survey 5-Year Estimates (2008-2012).
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-34 September 2016

Figure 3-6: Employment Density in the Project Area

Source: US Census Bureau, American Community Survey 5-Year Estimates (2008-2012).
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-35 September 2016

3.6.3.2 Environmental Justice

Table 3-14 shows the income, poverty, and minority statistics based on the 2010 U.S. Census for all 

counties in the Project Area. Table 3-15 shows the number of census tracts within 500 feet of the 

centerline of each corridor with high concentrations of low income and minority populations. As this 

table is intended to present the effects of the corridors, it does not include Project Area counties that 

the corridors do not traverse. Figure 3-7 shows that more urbanized areas have higher densities of 

minority and low-income populations compared with rural areas. The ratio of EJ areas to non-EJ 

areas within each corridor alternative when measured by linear mile along each corridor is 1:0.6 for 

the I-75 Corridor Alternative (i.e. one EJ area per 0.6 linear miles) and 1:1.1 (i.e. on EJ area per 1.1 

linear miles) for the East and I-75/Rome Corridor Alternatives. 

Table 3-14: Project Area Income and Poverty Status by County

County 2010 Population 2012 Median 

Household Income

% Below 

Poverty % Minority

Bartow, GA 100,157 $46,014 16.0% 20.3%

Catoosa, GA 63,942 $47,676 12.2% 7.5%

Chattooga, GA 26,015 $32,825 20.7% 17.1%

Cherokee, GA 214,346 $66,065 8.4% 18.7%

Clayton, GA 259,424 $37,767 21.5% 85.9%

Cobb, GA 688,078 $61,791 11.9% 43.7%

Douglas, GA 132,403 $54,526 13.4% 50.8%

Floyd, GA 96,317 $39,933 20.9% 26.3%

Fulton, GA 920,581 $55,491 16.7% 59.2%

Gordon, GA 55,186 $40,562 19.9% 20.1%

Murray, GA 39,628 $32,618 19.8% 15.0%

Paulding, GA 142,324 $60,282 10.3% 25.0%

Polk, GA 41,475 $50,202 21.7% 26.7%

Walker, GA 68,756 $52,328 16.5% 8.0%

Whitfield, GA 102,599 $39,575 19.4% 37.8%

Hamilton. TN 336,463 $59,426 16.2% 28.0%

Total 3,287,694 $48,568 15.9% 50.6%

Sources: U.S. Census Bureau 2010 population, Minority population - 2010 Census; Median Household Income, Pct. 

Below Poverty - American Community Survey, 5-Year Summary (2008-12)

Table 3-15: Number by Corridor of Census Tracts with High Concentrations of Environmental 

Justice Populations in the 1,000-foot Study Area (2010)

County

I-75 Corridor Alternative East Corridor Alternative I-75/Rome Corridor

Alternative

Low 

Income Minority Both Low Income Minority Both Low Income Minority Both

Bartow, GA 3 2 1 2 2 1 4 4 2

Catoosa, GA 3 3 1 1 1 0 3 3 1

Clayton, GA 1 1 1 1 1 1 1 1 1

Cherokee, GA 1 1 1 1 1 1 1 1 1

Cobb, GA 11 10 8 11 10 8 11 10 8

Paulding, GA 0 0 0 0 0 0 0 0 0

Floyd, GA 0 0 0 0 0 0 0 0 0

Fulton, GA 19 18 17 19 18 17 19 18 17

Gordon, GA 3 4 3 2 0 0 3 4 3

Murray, GA 0 0 0 1 1 0 0 0 0

Whitfield, GA 1 2 1 3 3 2 1 2 1

Hamilton. TN 8 8 8 9 8 8 8 8 8

Total Study Area 50 49 41 50 45 38 51 51 42

Sources: U.S. Census Bureau 2010 population, Minority population - 2010 Census; Median Household Income, Pct. Below Poverty 

- American Community Survey, 5-Year Summary (2008-12)
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-36 September 2016

Figure 3-7: Environmental Justice Populations in the Project Area

Sources: U.S. Census Bureau (2010 population, Minority population - 2010 Census; Median Household Income, Pct. Below Poverty 

- American Community Survey, 5-Year Summary (2008-12))
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-37 September 2016

3.6.3.3 Public Involvement

FRA, GDOT, and TDOT have striven for fair and meaningful involvement of all populations within the

Project Area in undertaking the public involvement program for the Project. The following public 

involvement activities were conducted for all populations, including EJ populations, in the Project 

Area. See also Chapter 7 for more information on the public outreach effort.

 Three public scoping meetings were held in September 2007 in Powder Springs and Rome, 

Georgia; and Chattanooga, Tennessee. Meetings were advertised in local newspapers, on 

GDOT’s website, and the Project website.

 Four public information open houses were held in November 2010 in Dalton, Atlanta, and 

Cartersville, Georgia; and Chattanooga, Tennessee. Spanish and Portuguese interpreters were 

available at each meeting. The following methods were used to announce these meetings: 

 Local newspaper advertisements;

 Project and GDOT website announcements;

 Flyer distributed to the contact database that was prepared as part of the public involvement 

effort, chambers of commerce, and other agencies in the Project Area (see Section 7.7.1

for more information about the stakeholder contact database); 

 Public service announcements sent to local radio stations;

 Online calendar announcements (WABE radio station and Access Atlanta website);

 Press releases distributed to GDOT’s media contact list;

 Flyers distributed by Chambers of Commerce by email blast and posting on their websites; 

and

 Two newsletters were distributed in spring 2008 and in fall 2010 that summarized the 

progress of the Tier 1 DEIS as well as upcoming events. 

3.6.4 Environmental Consequences

3.6.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. As the geographic scope and 

nature of the No-Build Alternative projects is limited, the potential effects of the projects are likely to 

be limited to the area in which the project is located.

Population and Employment: In the No-Build Alternative, the mobility and accessibility in the 

region would be limited to the existing transportation network and transit services, and identified 

highway projects. The limited scope of highway and transit improvements may not adequately 

address the projected population and employment growth, or transportation needs of the Project 

Area. Traffic congestion and associated delays could continue to grow. The No-Build Alternative 

would have no additional direct effects beyond those included in planned transportation 

improvements for the Project Area.

Economic: The roadway and transit improvements in the No-Build Alternative would likely benefit

economic development within portions of the Project Area where the improvements occur. Given the 

limited scope of these transportation improvements, the potential change in market access is 

unlikely to change how local or regional employers plan and implement their competitive reach into 

supplier, customer, and labor markets. The limited scope of No-Build Alternative projects is not 

anticipated to affect the public sector substantially in terms of tax revenues, services, and land use. 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-38 September 2016

Environmental Justice: All populations, including EJ populations, may experience changes in 

mobility in the existing transportation network and transit services in the No-Build Alternative 

because of increased demand arising from population and employment growth over time. The 

limited scope of highway and transit service improvements may not adequately address the 

transportation needs of projected population and employment in the Project Area. This condition 

would be borne by all populations. The assessment of whether the projects in the No-Build 

Alternative would be disproportionately high and adverse would be the responsibility of the sponsors

of those projects. In the No-Build Alternative, the mobility benefits that would be provided by the 

Corridor Alternatives would not occur.

3.6.4.2 Corridor Alternatives

Population and Employment: The Corridor Alternatives would improve mobility in the region by 

adding a new mode of transportation. The Corridor Alternatives also would increase the accessibility 

of the populations within the proposed station areas to employment, air transportation, and 

opportunities for education, recreation, and commercial facilities. Not all Corridor Alternatives serve 

the same proposed station locations. For example, only the I-75/Rome Corridor Alternative serves 

the proposed Rome station location, and only the East Corridor Alternative serves the proposed

Dalton-Chatsworth station location. Therefore, depending on the Corridor Alternative, increased 

accessibility would be provided differently among the Corridor Alternatives. 

Similar to the No-Build Alternative, population and employment levels within the Project Area are 

expected to increase by 2030. In particular, the largest population and employment increases are 

expected to occur within the Atlanta and Chattanooga metropolitan regions. The population and 

employment levels would be expected to further increase due to land development expected to 

occur at proposed station locations as an indirect effect of the Project. The mobility benefit of the 

new HSGT service may increase the rate of population and growth of the towns and communities in 

the proposed station locations. Table 3-16: shows the population within a 10-mile radius of the 

proposed station locations and employment within a 5-mile radius of the proposed station locations. 

The I-75/Rome Corridor Alternative would serve the largest population and employment.

Table 3-16: Population and Employment near the Proposed Stations

Corridor

Alternative

Population within 10-miles of 

Proposed Stations (millions)

Employment within 5-miles of 

Proposed Stations (thousands)

I-75 2.85 867

East 2.86 870

I-75/Rome 2.95 894

Sources: US Census Bureau, American Community Survey 5-Year Estimates (2008-2012).

Populations along the Corridor Alternatives could experience either potential direct effects such as 

property acquisition or physical alterations to property, or proximity effects, such as noise, access, or 

visual effects. Visual and noise effects could be more noticeable along sections of elevated rail or 

guideway and in areas adjacent to storage yards. 

Economic: The potential for any Corridor Alternative to affect economic development, compared to 

the No-Build Alternative, was assessed in two ways: first by considering the potential for contingent 

development that could occur surrounding proposed station locations, and, second and more 

broadly, by considering development triggered by improved market access conditions across the 

entire transportation network within the Project Area. The potential market access improvement that 

would be offered by the Corridor Alternatives matters to existing and prospective employers as they 

gauge their competitive reach into supplier, customer, and labor markets. Wider market reach results 

in productivity and cost benefits, which ultimately support job growth greater than the No-Build 

Alternative. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-39 September 2016

The potential growth in population resulting from the potential increase in economic activity also 

would affect the public sector by increasing tax revenues while also increasing the need for 

educational, health care, and recreational facilities. Potential economic impacts would tend to be 

localized and stem from indirect effects such as changes in land use that in turn cause economic 

activity shifts, or land takings in settings with a lack of available parcels to accommodate business 

relocations or future intended development. Potential direct localized economic effects could result if 

motor vehicle traffic must be re-routed such that access to businesses and general mobility is 

affected. 

Environmental Justice: As described for population and employment in general, not all Corridor 

Alternatives would serve the same proposed station locations or the same EJ populations. 

Depending on the Corridor Alternative, some EJ populations in the Project Area would be served 

and some would not. In addition, the ratio of EJ areas to non-EJ areas within each Corridor 

Alternative when measured by linear mile along each corridor (1:0.6 for the I-75 Corridor Alternative 

and 1:1.1 for the East and I-75-Rome Corridor Alternatives). However, most EJ census tracts are 

located in Cobb, Fulton, and Hamilton counties, all of which would be served by each of the Corridor 

Alternatives.

The use of existing ROW would minimize impacts to all communities; therefore, the Project Team 

anticipates the potential for disproportionately high and adverse effects to minority or low-income 

communities would be minimal due to the use of exclusive, grade-separated rail or guideway within 

existing right-of-way. The Project Team does not anticipate disproportionately high and adverse

noise and vibration effects because the proposed service would be grade separated; however, the 

Project Team recognizes that the rail or Maglev equipment would also generate noise and that 

additional analysis during the Tier 2 NEPA phase will be required for a final determination. Potential 

benefits of the Corridor Alternatives could include, but are not limited to, improved mobility and 

access to regional destinations, reduced travel times, lower commuting costs, and greater 

employment opportunities. These benefits would be experienced by all populations within the Project 

Area. 

Acquisition and Relocation: The Project could have negative effects on populations and 

businesses within the Project Area due to the potential need to acquire property for ROW. However, 

since the Project would be constructed within existing ROW wherever reasonably feasible, the 

number of acquisitions and relocations is expected to be minimized. The I-75 Corridor Alternative 

would potentially have the least negative effects regarding acquisitions and relocations because it 

follows the existing I-75 ROW. The potential for property acquisition and the relocation of residents 

and businesses will be studied in the Tier 2 NEPA process.

Community Cohesion: The Project could result in a disruption to community cohesion. If a 

proposed station or HSGT guideway is built within an existing neighborhood or community, it could 

act as a divide that physically separates a population from the surrounding community. The potential 

for this to occur will be evaluated further during the Tier 2 NEPA process.

In addition to permanent effects, all populations may experience temporary effects during 

construction, including effects to access and construction traffic, noise, and visual effects. The 

determination of whether construction activities would result in disproportionately high and adverse 

effects to EJ populations in identified communities will be evaluated during the Tier 2 NEPA process

when a construction plan has been developed and specifics on the construction phase, such as 

staging areas and timing, are determined.

3.6.5 Potential Mitigation

At this corridor level of analysis, site-specific locations of proposed HSGT guideway, stations and 

facilities, as well as their potential effects, have not been identified. As a result, it is premature to 

evaluate potential mitigation. If a Corridor Alternative is selected and design of the Project is further 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-40 September 2016

defined and delineated in the Tier 2 NEPA process, potential impacts on socioeconomic conditions 

and EJ communities will be identified in detail. At that time, GDOT and TDOT will refine the selected 

alternative to avoid or minimize Project effects and identify mitigation commitments to address 

remaining impacts.

The types of mitigation GDOT and TDOT could implement will depend on the nature and extent of 

impacts (e.g., displacements, noise and vibration impacts, access, visual, and safety). Public and 

agency input would help identify appropriate mitigation. Potential site-specific mitigation strategies 

might include accommodation of pedestrian access at proposed station sites, measures to reduce 

the impacts of noise and vibration, coordination with localities to determine primary emergency 

routes, and construction Best Management Practices to lessen the temporary effects on area 

residents. Mitigation would be implemented to Georgia and Tennessee state guidelines and policies.

If it is not possible to avoid property impacts, mitigation measures will include providing relocation 

assistance and compensation, as appropriate, to affected property owners, in conformance with the 

Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended (42 

U.S.C. 4601 et seq.). This law requires that fair and equitable assistance be provided to those 

persons displaced by federal or federally funded actions. GDOT and TDOT are committed to 

avoiding or minimizing Project effects and implementing mitigation where warranted, effective and 

reasonably feasible.

3.6.6 Subsequent Analysis

In the Tier 2 NEPA process, the proposed station locations, storage and maintenance facility 

location, and exact alignment configuration will be determined, at which time a more in-depth 

analysis will be conducted. The analysis will include, but will not be limited to, the following:

 Effects of property displacements and business impacts of these displacements and relocation 

studies;

 Effects on community cohesion within residential neighborhoods;

 Effects on children, including environmental health risks or safety risks that are attributable to 

products or substances that children are likely to come in contact with or ingest;

 Effect of population and employment changes and growth, and corresponding demands for 

housing (and potentially TOD); 

 Effects on the visual and aesthetics of the surrounding communities;

 Effects on station and pedestrian access and vehicular traffic circulation on roadway networks 

around HSGT stations; and

 Effects of the proposed project on community facilities.

For EJ, a more detailed and refined study will be completed to specifically document the presence of 

low-income and minority communities, and then to evaluate whether and where disproportionately 

high and adverse effects on those communities could occur. Within the Tier 2 process, the most 

recent U.S. Census block group data will be used to map the low-income and minority populations 

within the Project Area. This level of data may identify additional EJ communities not identified in the 

Tier 1 analysis, which uses Census tract data. In addition, information on potential minority and lowincome communities will be gathered through public outreach activities such as listening sessions, 

community meetings, and one-on-one conversations with public officials. These activities will provide 

GDOT and TDOT with a better understanding of the demographics of the communities and the 

issues and concerns EJ communities may have. Using this information, the Tier 2 process will 

document the locations and characteristics of these communities and document issues of concern.

The effects analysis will consider the benefits of the Project as well as the potential for 

disproportionately high and adverse effects to EJ populations. In addition to issues and concerns 

raised by the identified populations, the assessment will consider the following:
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-41 September 2016

 Number of acquisitions in EJ communities versus in the general reference population;

 Number of noise and vibration impacts in EJ communities versus in the general reference 

population;

 Number of impacts to park and recreation facilities in EJ communities versus in the general 

reference population;

 Effects on community cohesion within residential neighborhoods; and

 Transportation and access effects in EJ communities versus in the general reference population

The effects analysis will also consider the benefits as well as potential for environmental health risks 

and safety risks that may disproportionately affect children. Potential risks could include, but are not 

limited to, effects on air quality, exposure to hazardous materials, and safety risks from at-grade 

crossings. The HSGT Project will ensure avoidance, minimization, or mitigation of any potential 

disproportionate risks to children.

The socioeconomic and EJ analyses also will consider the potential construction impacts of the 

Project and will identify warranted and reasonably feasible mitigation measures for potential effects. 

3.7 Parklands, Wildlife Refuges, and Recreation Areas

This section identifies parklands, wildlife refuges, and recreation areas within the Project Area as 

well as a qualitative assessment of the potential effects of the Corridor Alternatives on those 

resources. A description of potential mitigation strategies is also provided.

3.7.1 Legal and Regulatory Context

Public parklands, recreation areas, wildlife and waterfowl refuges as well as historic properties listed 

on the National Register for Historic Places (NRHP) are protected under Section 4(f) of the U.S. 

Department of Transportation Act of 1966. Section 4(f) states that the Secretary of the USDOT shall 

not approve any program or project that requires the “use” of any land from a public park, recreation 

area, wildlife and waterfowl refuge, or historic site, unless there is no feasible and prudent 

alternative, and such project or program includes all possible planning to minimize harm.13 For 

further discussion regarding this issue, refer to Chapter 4 of this Tier 1 DEIS. 

Parklands that have received funding from the Land and Water Conservation Fund Act (LWCF) are 

afforded additional protection under Section 6(f) of the LWCF. Under Section 6(f), the United States 

Department of the Interior (USDOI) provides funding for state, county, and local efforts to advance 

public recreation. Once LWCF funds are utilized for a particular recreation project, conversion of that 

park facility for any non-recreational purpose is prohibited unless alternatives are assessed and 

steps are taken to identify, evaluate, and supply replacement parkland. In addition, the Secretary of 

Interior must grant prior approval for the conversion and replacement parkland.

3.7.2 Methodology

The study area for the parklands, wildlife refuges, and recreational areas analysis is defined as a 

1,000-foot wide corridor consisting of 500 feet on each side of the centerlines of the proposed 

Corridor Alternatives. This area is sufficiently wide to:

 Encompass and account for potential effects from the improvements associated with each 

Corridor Alternative including infrastructure improvements (such as embankments, aerial 

structures, track improvements), ancillary facilities (such as stations, yards and parking 

structures), or service changes.

 

13 Historic and cultural resources are discussed in Section 3.8.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-42 September 2016

 Account for contiguous parklands and wild and scenic rivers that may extend beyond the 

Corridor Alternative.

 Consider areas outside of the Corridor Alternative for proximity effects related to noise and 

vibration and visual and aesthetic changes. While noise and vibration, and visual and aesthetic 

changes could extend beyond the 1,000 feet, this methodology assumes that the more 

prominent effects would occur close to the proposed HSGT improvement.

Sources of information include city and county websites, the GDNR EPD, National Park Service, and 

the U.S. Forest Service. 

At this corridor level of analysis, potential effects to parklands, wildlife refuges and recreation areas

are broadly described qualitatively. Since site-specific locations of the proposed HSGT guideway, 

stations and facilities, as well as their potential effects, have not been identified, it is premature to 

determine precise Project effects on parks, wildlife refuges, and recreation areas. If a Corridor

Alternative is selected and design is further defined and delineated in the Tier 2 NEPA process, 

potential impacts on these resources will be identified in detail. 

3.7.3 Affected Environment

In the 1-75 Corridor Alternative, there are 443 acres of parklands, wildlife refuges, and recreation 

areas; in the East Corridor Alternative, there are 447 acres; and in the I-75/Rome Corridor 

Alternative, there are 442 acres. Table 3-17 lists the parklands, wildlife refuges, and recreation 

areas within each Corridor Alternative and identifies the owner or location for those resources for 

which the owner is not known. Currently, no Section 6(f) resources are known to occur in the Project 

Area. Figures 3-9 and 3-10 show the locations of identified resources. 

3.7.4 Environmental Consequences

3.7.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. In the No-Build Alternative, the 

impacts to parklands, wildlife refuges, and recreation areas could potentially occur if additional ROW

is needed or if substantial changes to traffic and transit volumes or operations lead to proximity 

effects such as changes in noise levels and visual effects. As the geographic scope and nature of 

the No-Build Alternative projects is limited, the potential effects of the projects are likely to be 

contained to the areas in which the projects are constructed. The potential for impacts to parklands, 

wildlife refuges, and recreation areas would be determined through the environmental processes for 

the already planned transportation improvements.

3.7.4.2 Corridor Alternatives

In this assessment and notwithstanding future design efforts to avoid or minimize potential impacts, 

the number of parklands, wildlife refuges and recreational facilities was used to suggest the relative 

potential for impact on or adverse effect to cultural resources. As shown in Table 3-17, the I-75 

Corridor Alternative potentially would affect 25 parks, wildlife refuges, and recreation areas; the East 

Corridor Alternative, 19; and the I-75/Rome Corridor Alternative, 30. The I-75/Rome Corridor 

Alternative has the highest number of parks, refuges or recreational areas in its study area and the 

highest potential for impacts on parkland resources. All three proposed corridors encompass the 

Chattahoochee River National Recreation Area, Lake Allatoona/Old 41 Recreation Area, Camp 

Jordan Park, and Brown Acres Golf Course. A small portion of Carters Lake is in the 1,000-foot 

buffer of the East Corridor Alternative. The East Corridor Alternative also encompasses a portion of 

Sand Mountain. The I-75 and I-75/Rome Corridor Alternatives are at the edge of the Resaca 

Battlefield.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-43 September 2016

Potential Project effects on parklands, wildlife refuges, and recreational resources include property 

acquisition, physical alterations to property, or proximity effects, such as noise, access, or visual 

effects. Visual and noise effects could be more noticeable along sections where the Project 

guideway is elevated. Beneficial effects to park, wildlife refuges, and recreational resources in close 

proximity to proposed station locations could occur as a result of improved access. 

Each Corridor Alternative has the potential to temporarily affect these resources during construction. 

Potential effects of construction could include access, traffic, noise, and visual impacts. As 

discussed in Chapter 4 of this Tier 1 DEIS, determinations of Section 4(f) use, such as temporary 

occupancy as defined in 23 CFR 774.13, will be made during the Tier 2 NEPA process.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-44 September 2016

Table 3-17: Parklands, Wildlife Refuges, and Recreation Areas within the Project Area

Resource Type Owner/Location

Corridor

I-75 East I-75/ 

Rome

Pryor-Tucker Playlot Park City of Atlanta, GA X X X

Fire Station #5 Park Park City of Atlanta, GA X X X

Pittman Park Recreational Facilities City of Atlanta, GA X X X

Ralph David Abernathy Median Park City of Atlanta, GA X X X

Windsor Street Park Park City of Atlanta, GA X X X

Rosa L. Burney Park Recreational Facilities City of Atlanta, GA X X X

Underwood Hills Park Recreational Facilities City of Atlanta, GA X X X

Beaverbrook Park Park City of Atlanta, GA X X X

Tennyson Circle Park City of Atlanta, GA X X X

Chattahoochee River National 

Recreation Area

Conservation/

Wildlife Refuge National Park Service X X X

Kennesaw Village Park Park Cobb County, GA X X X

Lake Acworth Recreation Area Conservation/

Wildlife Refuge

US Army Corps of 

Engineers X X X

Old 41 Recreation Area Conservation/

Wildlife Refuge

US Army Corps of 

Engineers X X X

Lake Allatoona Conservation/Wildlife 

Refuge/Park

US Army Corps of 

Engineers X X X

James A White Memorial Park/Pine 

Log Wildlife Management Area 

Conservation/

Wildlife Refuge State of Georgia - X -

Shannon Park Recreational Facilities Rome-Floyd Parks and 

Recreation Authority, GA - - X

Plainville Recreation Center Park City of Plainville, GA - - X

Gordon County Greenspace Conservation/

Wildlife Refuge Gordon County, GA X - X

Carter's Lake U.S. Army Corps of 

Engineers

US Army Corps of 

Engineers - - X

Resaca Battlefield Battlefield State of Georgia X - X

Chattahoochee National Forest Conservation/

Wildlife Refuge USDA Forest Service X - X

Dug Gap Elementary School Recreational Facilities Whitfield County, GA X - X

Whitfield County Greenspace Conservation/

Wildlife Refuge Whitfield County, GA X - X

Edwards Park Park Whitfield County, GA - X -

Hackett Field Recreational Facilities City of Ringgold, GA X - X

Sand Mountain Conservation/

Wildlife Refuge

U.S. Army Corps of 

Engineers - - X

Jack Mattox Park Complex Recreational Facilities Catoosa County, GA X - X

Catoosa County Greenspace Conservation/

Wildlife Refuge Catoosa County, GA - - X

Camp Jordan Park Recreational Facilities City of East Ridge, TN X - X

Brown Acres Golf Course Recreational Facilities City of Chattanooga, TN X X X

Warner Park and Zoo Park City of Chattanooga, TN X X X

Lincoln Park Recreational Facilities City of Chattanooga, TN X X X

Total Number of Resources 25 19 30

Sources: See list in Section 3.6.2
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-45 September 2016

Figure 3-8: Parklands, Wildlife Refuges, and Recreation Resources – Project Area South

Sources: See list in Section 3.6.2
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-46 September 2016

Figure 3-9: Parklands, Wildlife Refuges, and Recreation Resources – Project Area North

Sources: See list in Section 3.6.2
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-47 September 2016

3.7.5 Potential Mitigation

At this corridor level of analysis, site-specific locations of the proposed HSGT guideway, stations and 

facilities, as well as their potential effects, have not been identified. As a result, it is premature to 

evaluate potential mitigation. If a Corridor Alternative is selected and design is further defined and 

delineated in the Tier 2 NEPA process, potential impacts on parks, wildlife refuges, and recreation 

areas will be identified in detail. At that time, GDOT and TDOT will refine the selected alternative to 

avoid or minimize Project effects and identify mitigation commitments to address remaining impacts.

The types of mitigation GDOT and TDOT will identify depends on the nature and extent of impacts 

(e.g., displacements, noise and vibration impacts, access, and safety). Public and agency input may 

help identify appropriate mitigation. Potential site-specific mitigation strategies might include 

replacement or enhancement of functions of parks, wildlife refuges, and recreational areas; and 

ongoing consideration during design of ways to minimize Project effects. GDOT and TDOT are

committed to avoiding or minimizing Project effects and implementing mitigation where warranted, 

effective and reasonably feasible. 

3.7.6 Subsequent Analysis

In the Tier 2 NEPA process, and if a Corridor Alternative is selected, GDOT and TDOT will inventory 

publicly owned parklands, wildlife refuges, and recreation areas within the selected Corridor 

Alternative. Detailed property mapping and information on the extent of public access, use and 

ownership for parklands, wildlife refuges, and recreation areas will be determined through 

consultation with public officials and property owners/officials with jurisdiction. Consultation will also 

be undertaken to determine the use of/impacts to resources, assess avoidance, work to minimize 

effects, and develop appropriate and reasonably feasible mitigation commitments where warranted 

and reasonably feasible. 

Each Corridor Alternative also has the potential to impact protected conservation lands which could 

include conservation easements, conservation banks, and mitigation sites. Tier 2 NEPA analyses 

will consider potential impacts to these sites as well as avoidance, minimization, and mitigation of 

effects. Any impacts to these sites (as with other federal lands) would have a higher mitigation ratio 

than typical impacts to non-protected lands. The cost of mitigating these impacts, if a monetary 

mitigation is chosen, will be higher than typical ratios of unprotected lands.

If required, GDOT and TDOT will complete a Section 4(f) evaluation that documents use of Section 

4(f) properties, including the extent to which a “permanent use”, “constructive use,” “temporary 

occupancy” of a property, or de minimis impact may occur (see Chapter 4 addressing potential 

Section 4(f) resources). In the case of a use, the evaluation will address Section 4(f) requirements as 

applicable involving feasible and prudent avoidance alternatives analysis, least harm alternative 

analysis, all possible measures to minimize harm documentation, and coordination with officials 

having jurisdiction, including ultimately, if necessary, the U.S. Department of the Interior. The 

Section 4(f) Evaluation will be circulated as part of Tier 2 NEPA document. If, during the Tier 2 

NEPA process, a Section 6(f) property is identified, a Section 6(f) Evaluation will be prepared and 

circulated.

3.8 Cultural Resources

This section provides a general overview of the cultural resources within the Project Area as well as 

a qualitative assessment of the potential effects of the Corridor Alternatives on these resources. The 

term “cultural resources” refers to a variety of built and natural places related to the “traditions, 

beliefs, practices, lifeways, arts, crafts, and social institutions of any community...” (U.S. Department 

of Interior, NPS 1998). The number of known historic resources within the Corridor Alternatives is a 

distinguishing factor that suggests varying potential for impacts among the Corridor Alternatives. 
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3.8.1 Legal and Regulatory Context

Section 106 of the National Historic Preservation Act (NHPA) of 1966 (as amended) and associated 

implementing regulations in 36 CFR Part 800 require federal agencies to take into account the 

effects of their undertakings14 on historic properties (any prehistoric or historic district, site, building, 

structure, or object listed on or eligible for listing on the National Register of Historic Places [NRHP]). 

36 CFR 800.16 defines historic properties to include archaeological sites, prehistoric and historic 

districts, sites, buildings, structures or any object that may be eligible for inclusion in the NRHP as 

maintained by the Secretary of the Interior. In order to qualify for inclusion, properties must meet 

certain criteria and possess integrity as defined by the Secretary. These criteria are set forth in 36 

CFR 60.4, and are defined below:

“The quality of significance in American history, architecture, archaeology, 

engineering and culture that is present in districts, buildings, structures and objects 

that possess integrity of location, design, setting, materials, workmanship, feeling 

and that are associated with events that have made a significant contribution to the 

broad patterns of our history; that are associated with the lives of persons significant 

in our past; that embody the distinctive characteristics of a type, period or method of 

construction, or that represent the work of a master, or that possess high artistic 

values, or that represent a significant and distinguishable entity whose components 

may lack individual distinction; and that have yielded, or may be likely to yield, 

information important in prehistory or history.”

Historic properties also are protected by Section 4(f), which prohibits actions by the Secretary of 

Transportation that require “use” of a historic property that is listed or eligible for inclusion in the 

National Register, unless a determination is made that there is no feasible and prudent alternative to 

the use of such land, and all possible planning has been undertaken to minimize harm to the Section 

4(f) property. This condition is discussed further in the Chapter 4 Preliminary Section 4(f) 

Evaluation.

While there are a number of cemeteries within the study area that have cultural significance, it 

should be remembered that the following applies under the NHPA:

“...cemeteries and graves are among those properties that ordinarily are not 

considered eligible for inclusion in the National Register of Historic Places unless 

they meet special requirements. The National Register Criteria for Evaluation include 

considerations by which burial places may be eligible for inclusion in the National 

Register. To qualify for listing under Criteria A (association with events (association 

with people), or C (design), a cemetery or grave must meet not only the basic 

criteria, but also the special requirements of Criteria Considerations C or D, relating 

to graves and cemeteries.”

There are, however, federal and state laws and regulations that must be considered regarding 

cemeteries. The federal statute that regulates cemeteries, in addition to the provisions of the NHPA, 

is the Native American Graves Protection and Repatriation Act of November 16, 1990, which 

protects Native American burial sites and Native American human remains, funerary objects, sacred 

objects, and items of cultural patrimony on Federal and tribal lands (NAGPRA 1990). In Georgia, the 

Abandoned Cemeteries and Burial Grounds (1991); 36-72-1 et seq., which strengthens cemetery 

protection laws by authorizing local governments to preserve and protect abandoned cemeteries, 

and to issue permits prior to any disturbance of burials. Additional information can be found at

http://georgiashpo.org/laws

 

14 The Advisory Council on Historic Preservation defines a Federal undertaking in 36 CFR 800.16(y) as a project, activity, or 

program funded in whole or in part under the direct or indirect jurisdiction of a Federal agency, including those carried out by or on 

behalf of a Federal agency; those carried out with Federal financial assistance; those requiring a Federal permit, license or approval; 

and those subject to State or local regulation administered pursuant to a delegation or approval by a Federal agency.
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In Tennessee, the most relevant laws and regulations are found in Tennessee Code Annotated 

(T.C.A.) 11-6-107d, which regulates the discovery of a human skeleton including notification of the 

Division of Archaeology; T.C.A. 46-4-101-104, which regulates the relocation of a cemetery; and 

T.C.A. 39-17-311 (Desecration of a venerated object) and T.C.A. 39-17-312, which regulate 

desecration. Additional information can be found at 

http://www.tn.gov/environment/docs/arch_historic-cemeteries.pdf

A traditional cultural property (TCP) is a place associated with the cultural practices or beliefs of a 

living community that (a) are rooted in that community's history, and (b) are important in maintaining 

the continuing cultural identity of the community. Examples include a location associated with the 

traditional beliefs of a Native American group about its origins, its cultural history, or the nature of the 

world; or a rural community whose organization, buildings and structures, or patterns of land use 

reflect the cultural traditions valued by its long-term residents (National Register Bulletin 38, 

Guidelines for Evaluating and Documenting TCPs). 

Each federal agency is required under Section 106 to identify all federally recognized Native 

American Tribes and Native American groups (32 CFR §229.7(b)(2)) having aboriginal or historic 

ties to its jurisdictional land and seek to determine through the relevant Tribal official(s) the location 

and nature of TCPs (32 CFR §229.7(b)(1). 

A “sacred site” is a specific, discrete, narrowly delineated location identified by a Native American 

Tribe or authorized Tribal representative to a federal agency as sacred by virtue of its religious 

significance to, or ceremonial use by, a Native American religion (Presidential E.O. 13007, Indian 

Sacred Sites, issued May 24, 1996). This order mandates that federal agencies accommodate Tribal 

access and use of Native American sacred sites to the extent practicable and avoid adverse impacts 

to such sites. TCPs and Native American Sacred Sites are not necessarily NRHP eligible, but are 

evaluated under NEPA (see 40 CFR §§1508.8, 1508.14).

3.8.2 Methodology

For purposes of this Tier 1 DEIS, the study area for cultural resources is defined as a 1,000-foot 

wide corridor consisting of 500 feet on each side of the centerlines of proposed Corridor Alternatives. 

The identification of resources within the study area of each Corridor Alternative was completed 

through the review of the literature available from the following sources: 

 National Register of Historic Places (NRHP) documentation on file with the Tennessee Historical 

Commission - Tennessee State Historic Preservation Office (SHPO);

 NRHP documentation on file with the Georgia SHPO;

 Georgia Department of Natural Resources (GDNR) survey;

 Coosa Valley Regional Development Center;

 Northwest Georgia Regional Commission;

 Atlanta Regional Commission;

 Natural Archaeological Historical Resources Geographical Information System (NAHRGIS) 

database;

 Georgia Historic Bridge Survey (GHBS); and

 Regional and local historical societies and county planning and zoning departments in Bartow, 

Catoosa, Cherokee, Clayton, Cobb, Douglas, Floyd, Fulton, Gordon, Hamilton, Murray, Paulding, 

Polk, and Whitfield counties.

To comply with Section 106 of the NHPA, based on this literature review, all properties in the study 

area were identified that are listed, or potentially eligible for listing, in the NRHP. Historic properties 

are above-ground and/or subsurface properties or sites, at least 50 years of age, that are either 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-50 September 2016

listed on, or eligible for listing on, the NRHP because they meet the criteria, described in Section 

3.8.2, established by the U.S. Department of Interior (USDOI), National Park Service (NPS) in 36 

CFR Part 60.

In this Tier 1 assessment and notwithstanding future design efforts to avoid or minimize potential 

impacts, the number of NRHP listed, eligible and potentially eligible cultural resources in a corridor 

was used to suggest the relative potential for direct or indirect impact on or adverse effect to cultural 

resources. After selection of a preferred corridor alternative, the Tier 2 NEPA process will include a 

detailed assessment of effects in compliance with Section 106.

3.8.3 Affected Environment

3.8.3.1 Listed and Potentially Eligible Standing Structures

Table 3-18 presents resources listed on the NRHP and Table 3-19 presents those that are 

potentially eligible for listing that are known to exist in the Project Area. Two of the listed resources 

are historic districts within the City of Atlanta. The potential exists for the Castleberry Hill District to 

be within an EJ census tract as it contains residential properties. The Means Street District, 

however, has no residents. In addition, four routes of the Trail of Tears and five Civil War battlefields 

identified by the National Park Service are found within the study areas of all three Corridor 

Alternatives while a sixth battlefield is within the Project Area of I-75 and I-75/Rome. Figures 3-10 to 

3-16 list the cultural resources located in the Project Area.

Table 3-18: Historic Resources Listed on the NRHP

Resource

Corridor Alternative

I-75 East I-75/Rome

Southern Belting Company Building X

Selig Company Building X X X

Westinghouse Electric Company Building X X X

Cooledge, F. J., and Sons, Company--Hastings' Seed Company X X X

Atlanta Spring and Bed Company--Block Candy Company X X X

Atlanta Buggy Company and Warehouse--Hatcher Bros. Furniture 

Company X X X

Southern Railway North Avenue Yards Historic District X X X

King Plow Company X X X

Ashby Street Car Barn X X X

Means Street Historic District X X X

Van Winkle, E., Gin and Machine Works X X X

Benham Place X

Carter's Quarters X

Castleberry Hill Historic District X X X

Freeman-Hurt House X

Chattanooga National Cemetery X X X

Total Number 12 15 13

Sources: Sources are listed in Section 3.8.2 Methodology
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Table 3-19: Historic Resources Potentially Eligible for Listing on the NRHP

Resource

Corridor Alternative

I-75 East I-75/Rome

1546 Bells Ferry Road X X X

1647 Bells Ferry Road X X X

Pickin' Barn House X

243 Broadacre Road X

26 Harris Lane X

2629 Mine Rd X X

Dillard house X X

Mt Zion AME Church X X X

Bradford Home X

4600 Hwy 411, 1 m N of Pine Log X

611 Dawnville Road X

707 Dawnville Road X

798 Dawnville Road X

800 Dug Gap Road(at Harris) X X

Keith house; Callahan house X

Cohulla Creek Bridge X

Box 187, Ramhurst X

Boyton United Methodist Cemetery X X

Coosawattee River metal truss railroad bridge X

Brooker Farm Road X

Burnt Hickory Road X

Swamp Creek Church X X

Coahulla Creek highway bridge X

E side North Avenue, just N of Lacey St. X

E side of Pinhook Road (CR 227), 0.2 m N of US 411 X

Strickland house; Strickland-Champion house X

Oakman store X

E side US 411, 1 m S of GA 156, 1 m N of Ranger X

Front Street & Grove in Graysville X

Graysville, Blackford & Front Sts X

Chickamauga Creek Bridge X

Maddox Hill Road X

Pitner Branch Little Creek highway bridge X

McGaughey Chapel Road, N side, 1 m W of McGaughey Chapel X

(CR 106), 1.8 m W of US 41 X

Horton house X

H. F. Hamrick house X

N side of Calhoun Street (CO236), 0.15 m W of US 411 X

John Gray Trimble house X

N side Plainville Rd (CR 479), at junction with CR 116; 733 P. Rd. X

Barnett House; Barnett Hotel X X

Hammond Grocery X

NW corner US 41 and Walker Street X X

H. F. Hamrick & Company; post office X

Old 411 Bridge X

Old Tennessee Hwy. X

Old US 411 at Seaboard RR X

S corner of CR 479 and Park Street X

S side Calhoun Street (CR 236), just W of railroad X

Lewis Ramseur house; Ramseur-Tate house X

SE side North Avenue, S of GA 53 X

SE side of CR 479, at junction with Scott Avenue X

Bill Wilbanks house X

Southeast corner of Bee Parson Road and Bagley Road X

SW corner Park Street & US 411 X

SW side CR 306/CS 600, S of CR 420 X

SW side of Miller Ferry Rd (CR 106), 1.8 m W of US 41 X
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Resource

Corridor Alternative

I-75 East I-75/Rome

Bill Taylor house X X

Dalton Carpet Jobbers X X

Tom Barks house X

W of US 411 near center of Ranger X

W side Dug Gap Road X X

Joseph Daniel Johnson house X X

W side US 411 X

J. W. Willis Store X

W side US 411 at Carters X

W side US 411 between Lacey St. and Part St. X

William Hopper house X

W side US 411, 0.5 m S of GA 156 X

W side US 411, just N of Calhoun Street (CR 236) X

Carter's Store X

Total Number 15 52 21

Sources: Sources are listed in Section 3.8.2 Methodology

CR: County Road

3.8.3.2 Listed and Potentially Eligible Archaeological Resources

Table 3-20 presents the number of archaeological resources known to exist within the Project Area

and indicates the corridor alternatives that potentially would affect each resource. The East Corridor 

Alternative has the most archaeological sites while the I-75 Corridor Alternative has the least. 

Table 3-20: Identified Archaeological Sites by NRHP Status

NRHP Status Corridor Alternative

I-75 East I-75/Rome

Recommended Eligible 5 3 4

Recommended Ineligible 10 22 8

To be determined 17 21 26

All Sites in Corridor Alternative 32 46 38

Sources: Sources are listed in Section 3.8.2 Methodology

3.8.3.3 Cemeteries

Table 3-21 identifies the cemeteries in the study area for each Corridor Alternative and indicates 

their NRHP eligibility status. In addition, the Chattanooga National Cemetery, included in Table 3-19, 

is a resource listed on the NRHP. It potentially could be affected by each of the three Corridor 

Alternatives.

Table 3-21: Identified Cemeteries Potentially Eligible for Listing on the NRHP

Sources: Sources are listed in Section 3.8.2 Methodology

Resource NRHP Status

Corridor Alternative

I-75 East I-75/Rome

Dixon Cemetery To be determined X X

Hale Cemetery To be determined X X

Old Graysville Cemetery To be determined X

Gresham Cemetery To be determined X X X

Berwin Cemetery To be determined X
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Figure 3-10: Cultural Resources – Clayton and Fulton Counties, Georgia

Sources: Sources are listed in Section 3.8.2 Methodology
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Figure 3-11: Cultural Resources – Cobb County, Georgia

Sources: Sources are listed in Section 3.8.2 Methodology
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Figure 3-12: Cultural Resources – Bartow County, Georgia

Sources: Sources are listed in Section 3.8.2 Methodology
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Figure 3-13: Cultural Resources – Floyd County, Georgia

Sources: Sources are listed in Section 3.8.2 Methodology
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Figure 3-14: Cultural Resources – Gordon and Murray Counties, Georgia

Sources: Sources are listed in Section 3.8.2 Methodology
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Figure 3-15: Cultural Resources – Whitfield and Catoosa Counties, Georgia

Sources: Sources are listed in Section 3.8.2 Methodology
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Figure 3-16: Cultural Resources – Hamilton County, Tennessee

Sources: Sources are listed in Section 3.8.2 Methodology
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3.8.3.4 Traditional Cultural Properties and Native American Sites

The Native American Tribes listed below and the GA Natural Heritage Program were notified during 

the scoping process.

 Alabama-Quassarte Tribal Town Creek 

Nation

 Muscogee (Creek) National Council

 Alabama-Coushatta Tribe of Texas  Poarch Band of Creek Indians

 Cherokee Nation Chickasaw Nation  Seminole Nation of Oklahoma

 Coushatta Tribe of Louisiana  Seminole Tribe of Florida

 Eastern Band of Cherokee Indians  Shawnee Tribe

 Eastern Shawnee Tribe of Oklahoma  Thlopthlocco Tribal Town

 Kialegee Tribal Town of the Creek Nation  United Keetoowah Band of Cherokee

 Muscogee (Creek) Nation

The SHPOs of Georgia and Tennessee, the United Keetoowah Band of Cherokee Indians, and the 

Tribal Historic Preservation Officer of the Seminole Tribe are confirmed Consulting Parties in the 

Section 106 process. Should GDOT or TDOT receive funding to complete Tier II NEPA 

documentation, FRA and the Project Team will undertake full consultation in accordance with 

Section 106 and 36 CFR Part 800, including identifying and reaching out to additional potential 

consulting parties.

The locations of traditional cultural properties and Native American sites, as well as archaeological 

sites, are maintained in confidence under various state and federal laws to protect them from 

intentional damage or destruction. To date, consultation with federally recognized Native American 

tribes, and both GA and TN SHPOs has not identified any Native American TCPs or Sacred Sites in 

the Corridor Alternatives’ study areas. All correspondence is available for review in Appendix E –

Public Involvement & Agency Coordination.

3.8.4 Environmental Consequences

3.8.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. In the No-Build Alternative, the 

impacts to cultural resources could potentially occur if additional ROW is needed or if substantial 

changes to traffic and transit volumes or operations lead to proximity effects such as changes in 

noise levels and visual effects. As the geographic scope and nature of the No-Build Alternative 

projects are limited, the potential effects of the projects are likely to be contained to the area in which 

the projects will be constructed. The potential for impacts to cultural resources would be determined 

through the environmental processes for the already planned transportation improvements.

3.8.4.2 Corridor Alternatives

As discussed in Section 3.8.2 of this Tier 1 DEIS, GDOT and TDOT identified all properties in the 

study area that are listed, or potentially eligible for listing, in the NRHP. After selection of a Tier 1 

Preferred Alternative, at which time the design of this Project will have progressed to a point 

sufficient to enable site-specific analyses of potential effects on protected cultural resources, the Tier 

2 NEPA process will include a detailed assessment of effects in compliance with Section 106. In this 

Tier 1 assessment, the number of NRHP listed, eligible and potentially eligible cultural resources in a 

corridor was used to suggest the relative potential for direct or indirect impact on or adverse effect to 

cultural resources. As described in the Section 106 regulations, potential adverse effects on 

architectural resources include direct physical effects that alter the characteristics of the historic 

property in a manner that diminishes the integrity of the property’s significant historic features. For 
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example, adverse effects occur due to the demolition of a standing structure resource either listed or 

determined to be eligible for listing on the NRHP or the alteration of the resource in a manner that

removes the character-defining features that qualify it for listing. Similarly, adverse effects on 

archaeological resources result from construction activity that disturbs the site. Potential indirect 

effects on architectural resources include installation of new signal systems or overheard bridges, 

which constitute a visual intrusion that diminishes the property’s integrity, thereby adversely affecting 

its historic significance and hence its eligibility for listing on the NRHP. 

In comparing the potential impacts of the Corridor Alternatives on cultural resources, it should be 

noted that, as indicated by Tables 3-19 and 3-20, the NRHP status of many of the identified 

resources has not been yet determined. Further, if a Tier 1 Preferred Corridor Alternative is selected, 

additional resources may be identified during any subsequent Tier 2 analysis. Each Corridor 

Alternative potentially affects the same resources where the routes are identical, for example

between the proposed locations of the HJAIA and Cartersville Stations and between I-75 in 

Tennessee and downtown Chattanooga. Where the corridors differ, the specific resources potential 

affected and the overall numbers of potentially affected resources differ. Given currently available 

information, Table 3-22 summarizes the relative quantities of cultural resources in each study area 

that have been identified to date.

Table 3-22: Summary of Identified Cultural Resources

Corridor 

Alternative

Historic Resources 

(NRHP Status)

Archaeological Resources 

(Recommended NRHP 

Status)

NRHP 

Sites 

(acres)

Civil War 

Battlefields 

(acres)

Cemeteries 

(number)

Listed

Potentially 

Eligible Eligible Ineligible TBD*

I-75 12 15 5 10 17 87 3,564 4

East 15 52 3 22 21 151 2,360 3

I-75/Rome 13 21 4 21 26 89 3,834 5

Sources: Tennessee Historical Commission - Tennessee SHPO 2010; Georgia SHPO 2010; Georgia DNR survey 2010; Coosa 

Valley Regional Development Center 2010; Northwest Georgia Regional Commission 2010; ARC 2010; GNAHRGIS database 

2010; GHBS 2010; and Regional and local historical societies and county planning and zoning departments in Bartow, Catoosa, 

Cherokee, Clayton, Cobb, Douglas, Floyd, Fulton, Gordon, Hamilton, Murray, Paulding, Polk, and Whitfield counties.

Note: The Historic Resources column includes all historic resources provided by the sources listed above. The NRHP column lists 

the acres for only those properties listed in the NRHP. Further research on the cultural resources located in the study area will be 

conducted in the Tier 2 NEPA process.

*To be determined.

Of the NRHP-listed historic resources, 12 occur in the common corridor sections. Outside this 

common area, the I-75 Corridor Alternative has no other resources within its study area, the East 

Corridor Alternative has three additional resources, and the I-75/Rome Corridor Alternative has one 

additional resource. Of the potentially eligible historic resources, three occur in the common corridor 

sections. Outside this common area, the I-75 and I-75/Rome Corridor Alternative study areas have 

11 resources, one additional resource is in the I-75 Corridor Alternative study area only, 49 are in the 

East Corridor Alternative study area, and 7 are in I-75/Rome Corridor Alternative study area.

In this assessment and notwithstanding future design efforts to avoid or minimize potential impacts, 

the number of NRHP listed, eligible and potentially eligible cultural resources in a corridor was used 

to suggest the relative potential for impact on or adverse effect to cultural resources. The I-75 

Corridor Alternative has a total of 32 potential impacts; the East Corridor Alternative has a total of 70 

potential impacts; and the I-75/Rome Corridor Alternative has a total of 38 potential impacts. Overall, 

the East Corridor Alternative has the highest number of cultural resources in its study area and the 

highest number of potential impacts on cultural resources in this assessment.
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3.8.5 Potential Mitigation

Potential mitigation measures are presented here in a general manner. If potential adverse impacts 

are determined through subsequent analysis, specific mitigation measures will be developed as 

warranted by GDOT and TDOT through consultation with the FRA, the SHPOs of Georgia and 

Tennessee, and other consulting parties in accord with NHPA Section 106 (ACHP 2004) and 

applicable state regulations. If NRHP-eligible archaeological sites cannot be avoided or protected, 

data recovery excavations could be conducted to mitigate the adverse impacts. Cemeteries and 

burials will be avoided to the extent feasible. Any effects to cemeteries that cannot be avoided will be 

treated in accordance with the federal and state requirements identified in Section 3.8.1 of this Tier 

1 DEIS. For any use of properties that are listed, or eligible to be listed, on the NRHP, in addition to 

Section 106 consultation, Section 4(f) of the USDOT Act requires a detailed evaluation as discussed 

in Chapter 4.

3.8.6 Subsequent Analysis

It should be noted that there are likely, as yet unidentified, resources to be identified, analyzed, 

assessed and avoided through an intensive cultural resources inventory to be conducted during the 

Tier 2 NEPA process. The Tier 1 DEIS does not define specific alignments. The Tier 1 DEIS is 

evaluating Corridor Alternatives. Alignments will be defined in the Tier 2 NEPA phase. At that time, 

all cultural resources 50 years old or older (or a time period determined in consultation with the 

SHPOs), will be identified through field work to complete the desktop identifications in Section 3.8.3.

All resources will be evaluated for whether or not they meet the NRHP criteria. FRA, GDOT, and 

TDOT will consider NRHP eligible or listed resources as Section 106 resources, which will also be

subject to Section 4(f). Officials with jurisdiction will be identified and consulted for potential Section 

106 resources. Consultation will be performed with public officials, property owners/officials with 

jurisdiction, SHPOs, tribal representatives, and other consulting parties regarding the effects of the 

Project on Section 106 resources and measures to minimize harm. 

As explained in a fact sheet by the Advisory Council on Historic Preservation (ACHP 2011), the 

federal agency implementing a project or providing assistance, licenses, permits, or approvals for a 

proposed project is responsible for consulting with stakeholders and completing Section 106 prior to 

making a final decision. Agencies initiate Section 106 reviews in consultation with State and Tribal

officials. Appointed by each state governor, the SHPO coordinates the state’s historic preservation 

program and consults with agencies during Section 106 review. Agencies also consult with federally 

recognized Native American tribes and Native Hawaiian organizations when historic properties of 

religious and cultural significance to them are involved. Other consulting parties, such as individuals 

or groups interested in historic preservation, should be invited to consult, too. In order for FRA, 

GDOT and TDOT to complete a Section 106 review for the Project, the following four steps will be 

undertaken:

1. Initiate Section 106 and determine if it applies to a given project; 

2. Identify historic properties in the Project Area; 

3. Assess the effect of the Project on identified historic properties; and 

4. Resolve adverse effects by exploring alternatives to avoid, minimize, or mitigate the effects. 

If it is found during Tier 2 that historic properties would be adversely affected by the Project, the 

Section 106 consultation process will conclude with the negotiation and execution of a legally 

binding agreement that outlines how the FRA, GDOT, and TDOT will resolve those effects. Potential

mitigation strategies could include data recovery excavations and design/engineering improvements 

to avoid possible negative effects.
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3.9 Water Resources

This section addresses the related water resource subjects of wetlands, streams and lakes, and 

floodplains that potentially would be affected by the Corridor Alternatives. It also briefly describes the 

potential impacts that the Project could have on water quality. A soils analysis and concerns relative 

to groundwater including the locations of aquifers and recharge areas will be investigated in the Tier 

2 NEPA analysis. The acreage of wetlands and streams potentially affected by the Corridor 

Alternatives is a distinguishing factor among the Corridor Alternatives.

3.9.1 Legal and Regulatory Context 

Several federal regulations have been developed to provide protections for wetlands and waters and 

are applicable to the proposed project, including Executive Order 11990, DOT Order 5660.1A, the 

Rivers and Harbors Act of 1899, and the Clean Water Act (CWA).

Georgia State Waters are defined by the Official Code of Georgia 12-7-1 and are protected by the 

Georgia Erosion and Sedimentation Control Act of 1975, in compliance with the National Pollutant 

Discharge Elimination System (NPDES) permit as required under Section 402 of the Clean Water 

Act (CWA). Tennessee’s water quality is regulated through the Water Quality Control Act, T.C.A. 

Section 69-3-101, and Rules of Tennessee Department of Environment and Conservation Division of 

Water Pollution Control, Chapter 1200-4-3. For stormwater discharges from transportation projects, 

a NPDES permit must be obtained and a stormwater management program in both Georgia and 

Tennessee must be developed.

Local communities that participate in the National Flood Insurance Program (NFIP) are responsible 

for administering Federal Emergency Management Agency (FEMA) policy, including regulating 

development in FEMA-designated floodplains. The list of participating local communities within 

the Project Area, all of which are in Georgia, from the Community Rating System Eligible

Communities, May 1, 2014, is provided below. Coordination between the FRA, GDOT, TDOT, 

local communities, and FEMA will be necessary during the Tier 2 NEPA process.

Counties Cities

Catoosa Austell Lake City

Cherokee Cartersville Marietta

Cobb College Park Morrow

Douglas EastPoint Roswell

Fulton Forest Park

Paulding

3.9.1.1 Wetlands and Streams

Section 404 of the Clean Water Act (33 U.S.C. 1344) regulates the discharge of dredged or fill 

material into waters of the United States, including wetlands. Fundamental is the precept that 

dredged or fill material should not be discharged into the aquatic ecosystem, unless it can be

demonstrated that such a discharge will not have an unacceptable impact either individually or in 

combination with known and/or probable impacts of other activities affecting the ecosystems of 

concern.

From a national perspective, the degradation or destruction of special aquatic sites, such as filling 

operations in wetlands, is considered to be among the most severe environmental impacts because 

the degradation or destruction of special sites may represent an irreversible loss of valuable aquatic 

resources. Guidelines, regulations, and a permitting program have been developed by the 

Environmental Protection Agency in conjunction with the Secretary of the Army acting through the 

Chief of Engineers under Section 404(b)(1) of the Clean Water Act (33 U.S.C. 1344) (1972). 
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Jurisdictional waters of the U.S., to which these guidelines and regulations apply, are defined by 33 

CFR Part 328.3(b) and are protected by Section 404 of the CWA, which is administered and 

enforced by the U.S. Army Corps of Engineers (USACE). The Project Area falls within the 

jurisdiction of three USACE districts: Savannah, GA, Nashville, TN, and Mobile, AL.

Section 401 of the Clean Water Act also requires that any applicant for a Section 404 permit also 

obtain a Water Quality Certification from the state or states in which the project is located. 

The legal authority to obtain federal program delegation to administer the CWA has been 

established in Georgia by the Georgia Water Quality Control (GWQC) Act, administered by the 

GDNR, and in Tennessee by the Tennessee Water Quality Control Act of 1977, administered by the 

Tennessee Department of Environment and Conservation. 

Additionally, Executive Order 11990 – Protection of Wetlands, (as implemented by the Department 

of Transportation by USDOT Order 5660.1A) directs federal agencies to avoid to the extent possible, 

the long and short term adverse impacts associated with the destruction or modification of wetlands 

and to avoid direct or indirect support of new construction in wetlands wherever there is a practicable 

alternative. It is DOT policy that new construction located in wetlands shall be avoided unless there 

is no practicable alternative to the construction and the proposed action includes all practicable 

measures to minimize harm to wetlands which may result from the construction. 

3.9.1.2 Floodplains

Executive Order 11988 – Floodplain Management and Protection, (as implemented by the 

Department of Transportation by USDOT Order 5650.2) directs federal agencies to avoid to the 

extent possible, the long and short term effects associated with the occupancy and modification of 

floodplains. It requires efforts to avoid direct or indirect support of development within 100-year 

floodplains wherever there is a reasonable alternative, and prohibits floodplain encroachments which 

are hazardous, not economically viable, result in incomplete uses of the floodplain, or would cause a 

critical interruption of an emergency transportation facility, a substantial flood risk, or an effect on the 

floodplain’s natural resource values. 

Projects that encroach upon 100-year floodplains must be supported with additional specific 

information. The USDOT Order 5650.2, Floodplain Management and Protection, prescribes “policies 

and procedures for ensuring that proper consideration is given to the avoidance and mitigation of 

floodplain effects in agency actions, planning programs and budget requests.” Environmental review 

documents should indicate potential risks and effects from proposed transportation facilities. 

Many, but not all, local governments within the Project Area, as listed above in Section 3.9.1,

participate in the NFIP, which limits the information available from some areas. In these NFIP 

communities, FEMA, in cooperation with other federal agencies and state and local governments, 

conducts detailed flood studies to determine designated floodways to safely convey floodwater 

during flood events. These studies result in floodway boundaries, which are illustrated on Flood 

Insurance Rate Maps (FIRMs). The information obtained through these studies is utilized by local 

jurisdictions in their land use and development ordinances and regulations to discourage 

development in flood prone areas. 

The Flood Disaster Protection Act (42 U.S.C. §§ 4001-4128 [FDPA]), requires the identification of all 

flood-prone areas, the provision of flood insurance where applicable, and the purchase of insurance 

for structures in special flood-hazard areas. The FDPA applies to any federally assisted project in an 

area identified as having special flood hazards. Projects should avoid construction in, or develop a 

design to be consistent with, FEMA-identified flood hazard areas. 
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3.9.2 Methodology

3.9.2.1 Wetlands

Wetlands are defined under the CWA as, "Those areas that are inundated or saturated by surface or 

groundwater at a frequency and duration sufficient to support, and that under normal circumstances 

do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands 

generally include swamps, marshes, bogs and similar areas."

The Project Team defined a defined as a 1,000-foot wide area surrounding each Corridor Alternative

for the wetlands analysis. Data from the US Fish and Wildlife Service (USFWS) National Wetlands 

Inventory (NWI) was accessed to identify and determine the total acreages of wetlands falling within 

the Project Area.

3.9.2.2 Streams and Lakes

The potential effects to perennial streams and lakes were measured by the number and area of 

crossings by each Corridor Alternative. Perennial streams, rivers, lakes, and other Jurisdictional 

Waters of the U.S., excluding the intermittent and ephemeral and the wetlands identified above, 

were determined by desktop survey.

The study area for the assessment of wetlands is defined as a 1,000-foot wide area surrounding 

each Corridor Alternative. Data from the USFWS NWI was accessed to identify and determine the 

total acreages of wetlands falling within the each study area.

3.9.2.3 Floodplains

A floodplain is defined by FEMA as the area adjoining a river or stream that has been or may be 

covered by floodwaters during storm events. A floodplain consists of two components: the floodway 

and the flood fringe: 

 The floodway is the mainstream or river channel and is the area regulated by federal, state, or 

local requirements to safely provide for the discharge of the base flood so the cumulative 

increase in water surface elevation does not rise to a point that it can cause damage to adjacent 

developed lands. FEMA establishes the amount of increase at one-foot, but state and local 

requirements can be more stringent. 

 The flood fringe is the land area between the floodway and the 100-year floodplain boundary 

and is usually associated with standing water, rather than flowing water.

Hundred-year floodplains were identified in the corridor study areas using data captured from either 

the Digital Flood Insurance Rate Map (DFIRM) or FEMA Quadrangle 3 (Q3) data, depending on the 

county. These areas were then measured and the measurements were summed to reflect the total 

acreage of floodplains within each study area.

Beyond this desktop analysis, a detailed investigation of the water resources and the effects of the 

Project on water resources will be undertaken in the Tier 2 analysis.

3.9.3 Affected Environment 

3.9.3.1 Wetlands 

The approximate acreages and number of water resources found within each corridor study area are 

shown in Table 3-23. Figures 3-17 through 3-23 illustrate the extent of wetlands in each corridor.
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Table 3-23: Water Resources in the Project Area

Corridor

Alternative

Wetlands 

(acres)

Stream Crossings 

(number)

Lakes 

(acres)

Floodplains 

(acres)

I-75 205 21 104 1,563

East 205 18 92 2,576

I-75/Rome 251 35 98 1,689

Sources: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; 

DFIRM and FEMA Q3 data

These data show the following regarding each Corridor Alternative study area:

 The I-75 Corridor Alternative has fewer acres of wetlands than the I-75/Rome Corridor 

Alternative and the same number of acres as the East Corridor Alternative. It has fewer stream 

crossings than I-75/Rome Corridor Alternative, but more than East Corridor Alternative. It also 

has the most acres of lakes and the least acres of floodplains.

 The East Corridor Alternative has fewer acres of wetlands than the I-75/Rome Corridor 

Alternative and the same number as the I-75 Corridor Alternative. It has the smallest number of 

stream crossings and acres of lakes. It also has the most acres of floodplains.

 The I-75/Rome Corridor Alternative has the most acres of wetlands and stream crossings. It has 

more acres of lakes than the East, but fewer than I-75, and more acres of floodplains than I-75, 

but fewer than the East.

3.9.3.2 Streams, Lakes, and Watersheds

The streams and lakes crossed by each alternative can best be described in the context of the 

watersheds formed by each hydrologic unit or watershed. The watersheds in the Project Area are 

shown on Figure 3-24 and described below. Table 3-24 presents the Hydrologic Unit Codes (HUC), 

the respective water bodies (streams and lakes) and segment descriptions, and use classifications 

for each watershed. With the exception of the Upper Chattahoochee Watershed for which no 

assessment is available, all watersheds are shown in the 303(d) list as having impaired waterbodies. 

Upper Flint - The Upper Flint River basin is located in north central Georgia and is approximately 

2,993 square miles. The Flint River begins at the southern edge of the Atlanta region in Clayton 

County, which includes the southern terminus of each Corridor Alternative. The basin drains to the 

south where it flows into Lake Seminole at the Florida state line, and eventually discharges to the 

Gulf of Mexico through the Apalachicola River. Major tributaries include Whitewater, Muckalee, 

Kinchafoonee, and Ichawaynochaway Creeks. 

Upper Ocmulgee - The Upper Ocmulgee watershed is located in north central Georgia and contains 

approximately 2,625 square miles. Between the proposed HJAIA station and the proposed 

Downtown Atlanta station, each Corridor Alternative is within the Upper Ocmulgee watershed. The 

Ocmulgee River is formed from the headwaters of the Yellow, Alcovy, and South Rivers, which begin 

along the southeastern edge of the Atlanta region in Fulton, DeKalb, and Gwinnett Counties. Major 

tributaries include the Little Ocmulgee and Towaliga Rivers and Tobesofkee, Echeconnee and Big 

Indian Creeks. 

Upper Chattahoochee - The Upper Chattahoochee watershed is located in northeast central 

Georgia and contains approximately 1,580 square miles. Between the proposed Downtown Atlanta 

station and the proposed Cumberland/Galleria station and part of the way to the proposed Town 

Center station, each Corridor Alternative is within the Upper Chattahoochee watershed. The 

Chattahoochee River headwaters are in northeast Georgia at Chattahoochee Gap, north of Helen, 

GA and approximately ten miles from the North Carolina state border. The river drains to the 
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southwest, and flows through the Atlanta region. Major tributaries in the vicinity of the project are 

Sope, Nancy, Rottenwood, Whitewater and Long Island Creeks.

Figure 3-17: Water Resources – Clayton and Fulton Counties, Georgia

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-18: Water Resources – Cobb County, Georgia

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-19: Water Resources – Bartow County, Georgia

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-20: Water Resources – Floyd County, Georgia

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-21: Water Resources – Gordon and Murray Counties, Georgia

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-22: Water Resources – Whitfield and Catoosa Counties, Georgia

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-23: Water Resources – Hamilton County, Tennessee

Source: USFWS National Wetlands Inventory 2010; U.S. Census TIGER line files 2010; DFIRM and FEMA Q3 data
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Figure 3-24: Watersheds

Sources: DFIRM and FEMA Q3 data 2010
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Table 3-24: Waters Classified in Regulations

Watersheds and United 

States Geological Survey 

(USGS) HUC

Water Body and Segment Use Classification

Upper Flint 

(HUC 03130005) Flint River, Woolsey Road to SR 16 Drinking Water, Fishing

Upper Ocmulgee 

(HUC 03070103)

Alcovy River, SR 81 to City of Covington Water Intake Drinking Water, Fishing

Big Haynes Creek, SR 20 to Bald Rock Road Drinking Water, Fishing Big Haynes Creek, SR 78 to confluence with Yellow River

Jackson Lake, South River at SR 36; Yellow River at SR 

36; and Alcovy River at Newton New Factory Road Bridge 

to Lloyd Shoals Dam

Recreation, Fishing

Ocmulgee River, SR 18 to Macon Water Intake Drinking Water, Fishing

Tobesofkee Creek, Lake Tobesofkee Recreation, Fishing

Towaliga River, Headwaters to SR 36 Drinking Water, Fishing

Towaliga River, SR 36 to High Falls Dam Recreation, Fishing

Yellow River, SR 24 to Porterdale Water Intake Drinking Water, Fishing

Upper Chattahoochee 

(HUC 03130001)

Chattahoochee River, Headwaters to Buford Dam Recreation, Fishing

Chattahoochee River, Buford Dam to Atlanta (Peachtree 

Creek)

Recreation / Drinking 

Water, Fishing1

Big Creek, SR 400 to City of Roswell Water Intake Drinking Water, Fishing

Etowah 

(HUC 03150104)

Etowah River, Cherokee Road 782 to Canton Water Intake Drinking Water, Fishing

Etowah River, Cherokee Hwy 20 to Allatoona Dam Recreation / Drinking 

Water, Fishing

Etowah River, Allatoona Dam to Cartersville Water Intake Drinking Water, Fishing

Oostanaula 

(HUC 03150103)

Oostanaula River, Confluence of Conasauga and 

Coosawattee Rivers to Calhoun Water Intake Drinking Water, Fishing

Oostanaula River, Confluence with Armuchee Creek to 

Rome Water Intake Drinking Water, Fishing

Coosawattee 

(HUC 03150102)

Ellijay River, Headwaters to Ellijay Water Intake Drinking Water, Fishing

Cartecay River, Headwaters to Ellijay Water Intake Drinking Water, Fishing

Coosawattee River, Confluence of Mountaintown Creek to 

Carters Dam Recreation, Fishing

Coosawattee River, US 411 to confluence of Conasauga 

River Drinking Water, Fishing

Conasauga 

(HUC 03150101)

Conasauga River, SR 2 to Dalton Water Intake Drinking Water, Fishing

Mill Creek, Headwaters to Dalton Water Supply Drinking Water, Fishing

Conasauga River, Waters within Cohutta Wilderness Area Wild and Scenic, Fishing Jacks Creek, Waters within Cohutta Wilderness Area

Middle Tennessee 

Chickamauga 

(HUC 06020001)

Tennessee River, Waters within Tennessee River Basin Recreation, Fishing

1 Specific criteria apply at all times when the river flow measured at a point immediately upstream from Peachtree Creek equals or exceed 750 

cubic feet per second (cfs) (Atlanta gage flow minus Atlanta water supply withdrawals).

Etowah - The Etowah River watershed is located in central north Georgia and contains 

approximately 1,865 square miles. Portions of each Corridor Alternative are within this watershed. 

The Etowah River originates in Murray County and joins the Oostanaula River in Rome, GA., to form 

the Coosa River that then flows into Alabama. Major tributaries include Little River and the Euharlee, 

Pumpkinvine, and Allatoona Creeks.

Oostanaula - The Oostanaula watershed, Hydrologic Units of the Coosa River Basin, is located in 

northwest Georgia and contains approximately 562 square miles. Portions of the I-75 and the I75/Rome Corridor Alternatives are within this watershed. The Oostanaula River is formed by the 

confluence of the Conasauga and Coosawattee Rivers. The basin drains to the south through 

Gordon and Floyd Counties. 
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Coosawattee - The Coosawattee watershed, a Hydrologic Unit of the Coosa River Basin, is located 

in northwest Georgia and southeast Tennessee and contains approximately 862 square miles. The 

East Corridor Alternative and a small portion of the I-75 Corridor Alternative are within this 

watershed. It originates in Murray County and flows westward into Gordon County where the 

Coosawattee meets the Conasauga River to form the Oostanaula River. Major tributaries include the 

Ellijay and Cartecay Rivers. 

Conasauga - The Conasauga basin, a Hydrologic Unit of the Coosa River Basin, is located in 

northwest Georgia and southeast Tennessee and contains 604 square miles. Portions of each 

Corridor Alternative are within this watershed. It originates in Murray County, flows northward into 

Tennessee, where it flows briefly westward before turning back south and flowing into Murray 

County, Georgia. From there the Conasauga flows southwest into Gordon County, where it 

converges with the Coosawattee River. 

Middle Tennessee Chickamauga - The Middle Tennessee Chickamauga watershed, referred to by 

the State of Tennessee as the Lower Tennessee Watershed is a sub-basin of the Tennessee River 

Basin. It is located in northwest Georgia, southeast Tennessee, and northwest Alabama. It contains 

approximately 604 square miles. Portions of each Corridor Alternative are within this watershed. The 

Tennessee River begins east of Knoxville, Tennessee. From there, it flows southwest through 

toward Chattanooga before entering Alabama. Major tributaries include Town Creek and the Elk and 

Flint Rivers. 

3.9.3.3 Floodplains

In general, each Corridor Alternative is primarily within developed and urbanized areas and areas of 

existing transportation ROW. Figures 3-19 through 3-24 show the 100-year floodplains identified 

through review of the Digital Flood Insurance Rate Map (DFIRM) and FEMA Quadrangle 3 (Q3) 

data.

3.9.3.4 High Priority Waters

The GDNR has designated a statewide list of 212 high priority waters. This list was created to 

protect important populations of high priority species and to protect or restore aquatic systems, 

which was part of a larger effort to develop a comprehensive wildlife conservation strategy for 

Georgia. A map of all high priority waters in the State of Georgia is shown in Figure 3-25.

3.9.4 Environmental Consequences 

3.9.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. In the No-Build Alternative, the 

impacts to wetlands, streams, lakes, and other water resources could potentially occur if additional 

ROW is needed or if substantial changes to traffic and transit volumes or operations lead to 

proximity effects such as increased impervious surfaces and associated runoff. As the geographic 

scope and nature of the No-Build Alternative projects is limited, the potential effects of the projects 

are likely to be confined to the area in which construction will occur. The potential for impacts to 

wetlands, streams, lakes, and other water resources would be determined through the 

environmental processes for the already planned transportation improvements.

3.9.4.2 Corridor Alternatives

Wetland Impacts: Permanent wetland impacts may occur in specific locations of each Corridor 

Alternative where new rail/guideway, HSGT stations, and parking areas are proposed in or adjacent 

to wetlands. Temporary, construction-related impacts could occur, such as at corridor crossings of 

waterways. The I-75/Rome Corridor Alternative potentially has the most acres of wetlands and, as a 
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result, the greatest potential to impact wetlands. The I-75 and East Corridor Alternatives have fewer 

acres of wetlands, and potentially less impact on wetlands.

Figure 3-25: High Priority Waters in Georgia

Source: GDNR Wildlife Resources Division 2005

Streams and Lakes: Potential direct impacts of the Project on streams and lakes include, but may 

not be limited to, permanent clearing of riparian vegetation, fill placement in waters, and stormwater

runoff from impervious surfaces. These actions may potentially alter the natural characteristics of 

water resources, resulting in changes in water temperature, increased nutrients and sedimentation, 

and alterations in stream channel circulation. The I-75/Rome Corridor Alternative has the highest 

number of stream crossings and a high number of lakes; for this reason, it has the Corridor 

Alternative with the greatest potential to affect streams and lakes. The I-75 and East Corridor 

Alternatives have somewhat fewer numbers of stream crossing and lakes, and relatively less 

potential to affect these resources.
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Floodplains: Permanent floodplain impacts may occur in specific locations where HSGT stations, 

parking areas, maintenance and storage facilities, and the guideway are introduced in or adjacent to 

these areas. The East Corridor Alternative has the most acres of floodplains and, therefore, the 

highest potential for floodplain impacts. The I-75 and I-75/Rome Corridor Alternatives have relatively 

fewer acres of floodplains, and therefore, relatively less potential for floodplain impacts.

Water Quality Impacts: Impacts to water quality may occur due to the addition of impervious areas 

at HSGT stations, parking areas, maintenance and storage facilities, and, to an extent to be 

determined, by the guideway, depending on the technology selected and the design of the 

guideway. In addition to the increased runoff rates and volume from these impervious areas, 

changes in drainage patterns would occur due to the piping of stormwater runoff into closed 

drainage systems that would have direct outfalls to receiving waters. If a Corridor Alternative is 

selected, detailed analysis in Tier 2 will determine the specific increase of impervious area that 

would result from the development of the selected Corridor Alternative.

Each Corridor Alternative potentially could have construction effects on water resources and water 

quality. Such effects can result from clearing of vegetation, exposure of soil exposed due to 

grubbing, earth moving and grading, and other construction-related activities. These activities may 

cause soil erosion and sedimentation in downstream waters. Effects on groundwater could also 

occur during blasting/drilling activities or through natural fissures. Temporary access for 

construction activities and equipment also may affect water resources. The presence of heavy 

equipment and construction-related chemicals during construction potentially would affect water 

resources by increasing the risk of contamination. 

3.9.5 Potential Mitigation 

Wetlands, Streams, and Lakes

FRA, GDOT, and TDOT embrace the USACE’s wetland mitigation policy of “no net loss of 

wetlands.” Avoidance, minimization, and compensatory mitigation will be applied in sequential order 

as the design of the Project advances. GDOT and TDOT will examine reasonably feasible ways to 

avoid affecting wetlands, streams and lakes that are appropriate to the scope and degree of the 

potential Project effects and practicable in terms of cost, existing technology, and logistics in light of 

the Project’s purpose. 

GDOT and TDOT will then examine appropriate and practicable steps to reduce the potential Project 

effects on wetlands, streams and lakes. These steps will be implemented through design 

refinements. Minimization will typically focus on decreasing the footprint of the Project in and near 

these resources. Other examples of minimization that will be considered include:

 Minimizing clearing and grubbing activity;

 Decreasing or eliminating discharges into streams;

 Minimization of activities within stream channels; and

 Use of spanning structures and bottomless culverts over streams.

Compensatory mitigation will be developed by GDOT and TDOT during the Tier 2 NEPA phase after 

potential effects have been avoided and minimized to the extent reasonably feasible. In anticipation 

of the possibility of incurring unavoidable wetlands impacts, GDOT and TDOT have preliminarily 

evaluated existing and proposed compensatory mitigation sites during preparation of the Tier 1 DEIS 

to better understand the general availability and costs of mitigation credits. The Regulatory In-lieu 

Fee and Bank Information Tracking System (RIBITS), accessed in November 2014, indicates that 

mitigation banks having credits that would serve the Project Area are potentially available. During 

the Tier 2 NEPA process, the Project Team will again consult RIBITS to ensure that the necessary 

mitigation banks are still potentially available.
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The cost of mitigation credits is a function of supply and demand. According to Mitigation 

Management, the exclusive sales agent for commercial mitigation banks wetland credits range from 

$7,500 to $20,000 per credit, while stream credits range from $25 to $30 per credit in Gordon and 

southern Whitfield Counties, to $45 in Bartow and Floyd Counties, to as high as $85 in Catoosa and 

northern Whitfield Counties in 2015. As the number of credits needed per Hydrologic Unit Code 

(HUC is defined in subsequent analysis), it will be easier to estimate the probable cost. There also is 

the potential opportunity for onsite mitigation for some wetlands, which will be examined in more 

detail during Tier 2 analysis. 

Floodplains

As with wetlands, streams and lakes, GDOT, and TDOT will examine reasonably feasible ways to 

avoid affecting floodplains that are appropriate to the scope and degree of the potential Project 

effects and practicable in terms of cost, existing technology, and logistics in light of the Project’s

purpose. Minimization strategies could include design aspects such as right angle crossings, typical 

section reductions, and increased numbers of bridge spans or span length. Mitigation will be 

developed by GDOT and TDOT after potential effects have been avoided and minimized to the 

extent reasonably feasible. Restoration of floodplains to be equivalent to the prior functions is a 

typical strategy that would be examined if warranted in the Tier 2 NEPA process.

3.9.6 Permits

Permits may be required for the Project prior to construction. GDOT and TDOT would obtain these 

permits after the conclusion of the Tier 2 NEPA process:

 Section 404 and 401 Permits: The placement of fill materials in wetlands/Waters of the U.S. 

requires a permit from the USACE under Section 404 of the CWA of 1977. The appropriate 

level of this permit is determined based on the type of fill activity and the amount and location of 

fill involved. Section 404 permit requirements will be determined through coordination with the 

USACE during the Tier 2 NEPA process. In addition, a Section 401 General Water Quality 

Certification will be required if any portion of the Project may result in a discharge into “Waters 

of the United States” or for which an issuance of a federal permit or license is required. The 

USACE cannot issue a Section 404 permit until a Section 401 certification is issued. Final 

determination of permit applicability lies with the USACE.

 U.S. Army Corps of Engineers: In accordance with 33 U.S. Code (USC) Section 408, any 

alteration of a USACE Public Works project will require USACE review and approval to ensure 

that the alteration does not adversely impact the USACE Public Works. Coordination may be 

required with the USACE Mobile District for impacts to or to cross Lake Allatoona or any 

streams/open waters considered a Public Works project within the Mobile Basin.

 U.S. Forest Service: The Project may require approval by the US Forestry Service (USFS) to 

traverse the Chattahoochee National Forest. 

 National Pollutant Discharge Elimination System (NPDES) Permit: This Project would 

require a NPDES permit, which requires preparation and implementation of an Erosion, 

Sedimentation, and Pollution Control Plan and a Comprehensive Monitoring Program. In 

Georgia and Tennessee, NPDES permits are obtained through the Georgia Soil and Water 

Conservation Commission and the Tennessee Department of Environment and Conservation.

 Tennessee Valley Authority (TVA): The Project would require a TVA Section 26a permit

because it would cross the South Chickamauga Creek, a tributary of the Tennessee River. The 

Section 26a permit applies to projects built across, along, or in the Tennessee River or any of 

its tributaries. They are issued by the TVA.

 Georgia Erosion and Sedimentation Act of 1975: The Georgia Erosion and Sediment Act of 

1975, as amended, prohibits land disturbing activities within 25 feet (horizontally measured) of 

warm water streams and state waters and within 50 feet of cold water streams without approval 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-80 September 2016

from the Director of the GDNR EPD. It is anticipated that vegetative buffer variances would be 

required for this Project. 

 National Park Service: The Project may require a permit from the National Park Service to use 

property within the Chattahoochee River National Recreation Area pursuant to Section 1.6 (a) 

of 48 FR 30275, June 30, 1983, as amended, which states that the activity authorized by a 

permit shall be consistent with applicable legislation, federal regulations and administrative 

policies, and based upon a determination that public health and safety, environmental or scenic 

values, natural or cultural resources, scientific research, implementation of management 

responsibilities, proper allocation and use of facilities, or the avoidance of conflict among visitor 

use activities will not be adversely impacted.

GDOT and TDOT would obtain all necessary permits.

3.9.7 Subsequent Analysis

If a Corridor Alternative is selected, subsequent analysis to further identify potential impacts on water 

resources would be undertaken for that alternative in Tier 2. The subsequent analysis would include 

the following.

 Field surveys of potential surface water impacts to further analyze potential impacts on water

quality and to seek required permits from the appropriate agencies.

 Analysis of how the Project would contribute to total additional impervious ground surfaces and 

the subsequent potential additional impacts on surface run-off. This analysis would also identify 

potential mitigation measures.

 Geotechnical assessments to ensure that the project would not pollute groundwater through 

natural fissures or during blasting/drilling activities. 

 Obtaining all necessary permits.

 The usage type of each stream in the project area will also be documented, as well as each 

stream’s status on the EPA 303(d) list of impaired waters.

 Field investigations and jurisdictional wetland delineations, which would include the 

quantification of wetland impacts.

 Determination of potential mitigation strategies to minimize potential effects. 

3.10 Biological Resources

This chapter describes the existing wildlife/aquatic species and their habitats within the 1,000-foot 

study area of the proposed Corridor Alternatives, reports the potential effects of the Project on these 

resources, and identifies potential mitigation that could be implemented to address potential effects. 

The number of known threatened and endangered species habitats potentially affected by the 

Corridor Alternatives is a distinguishing factor among the Corridor Alternatives.

3.10.1 Legal and Regulatory Context

The following federal and state regulations provide the regulatory context for biological resources:

 Endangered Species Act: Section 7 of the Endangered Species Act (ESA) of 1973 (16 U.S.C. 

§1536), requires that any action likely to affect a species classified as federally-protected be 

subject to review by the USFWS. Critical habitat is a term defined and used in the Act. It is a 

specific geographic area(s) that is essential for the conservation of a threatened or endangered 

species and that may require special management and protection. Critical habitat may include an 

area that is not currently occupied by the species but that will be needed for its recovery.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-81 September 2016

 Migratory Bird Treaty Act: The Migratory Bird Treaty Act (16 U.S.C. §§ 703–712) protects all 

native migratory game and non-game birds with exceptions for the control of species that cause 

damage to agricultural or other interests in the U.S. and its territories. (50 CFR 10.13, List of 

Migratory Birds) 

 Bald and Golden Eagle Protection Act: The bald eagle is protected under the Bald and 

Golden Eagle Protection Act (16 U.S.C. § 668) (BGEPA). The BGEPA prohibits anyone, without 

a permit issued by the Secretary of the Interior, from "taking" bald eagles, including their parts, 

nests, or eggs. The bald eagle is listed as threatened by the State of Georgia and is state listed 

as “Deemed in Need of Management” in Tennessee.

 Georgia Environmental Policy Act (GEPA) of 1991: GEPA (O.C.G.A. § 12-16-1) protects the 

cultural and natural resources of Georgia that may be impacted by a state government agency’s 

actions.

 Georgia Wildflower Preservation Act of 1973: The Georgia Wildflower Preservation Act 

(O.C.G.A. §§ 12-6-170) Provides for the designation of officially protected plants and authorizes 

rules for the collection, transport, sale and listing of these plants.

 Georgia Endangered Wildlife Act of 1973: The Georgia Endangered Wildlife Act (O.C.G.A. §§ 

27-3-130) provides for the designation and protection of rare, threatened and endangered 

species within the State of Georgia.

 Tennessee Scenic Rivers Act of 1968: This Act (Acts 1968, ch. 540, §§ 1, 2; T.C.A., § 11-

1401) establishes the policy to preserve the scenic river system for aesthetic, ecological, and 

other scientific reasons. Priority is given to the preservation of natural, unspoiled, undeveloped 

river areas to assure preservation and to provide proper management of the recreational, wildlife 

and other land and water resources. 

 Tennessee Natural Areas Preservation Act of 1971: The Tennessee Natural Areas 

Preservation Act (Acts 1971, ch. 116, § 1; T.C.A., § 11-1701) authorizes the Department of 

Environment and Conservation, Bureau of Parks and Conservation, Division of Natural Areas to 

manage the Natural Areas Program through which State Natural Areas have been designated 

and their use is governed; and the Natural Areas Registry that develops non-binding voluntary 

agreements with private and public landowners to protect sites of ecological importance.

 Tennessee Non-game and Endangered or Threatened Wildlife Species Conservation Act 

of 1974: The Tennessee Non-game and Endangered or Threatened Wildlife Species 

Conservation Act (Acts 1974, ch. 769, § 1; T.C.A., § 51-901) provides protection for nongame 

wildlife and provides protection and management of endangered and threatened species within 

the state.

 Tennessee Rare Plant Protection and Conservation Act of 1985: The Tennessee Rare Plant 

Protection and Conservation Act (Acts 1985, ch. 242, § 1; T.C.A., § 11-26-201) requires written 

permission from a landowner or manager before removing or destroying state-listed endangered 

plant species, and requires nurseries to be licensed to sell state listed endangered plant species.

 Tennessee Water Control Act of 1977: The Tennessee Water Control Act (Acts 1971, ch. 164, 

§ 1; 1977, ch. 366, § 1; T.C.A., § 70-324) requires permitting for discharges of wastewater and 

monitors contamination to aquatic species habitats.

3.10.2 Methodology

A Geographic Information Systems (GIS) map of recorded, limited site-specific accounts of terrestrial 

protected species, and more broadly based species locations for aquatic species, as well as areas 

designated as critical habitat was overlaid onto Project Area mapping utilizing a GIS database 

maintained by the USFWS (http://www.fws.gov/athens/endangered.html). The number of instances 

where a Corridor Alternative potentially crosses an area designated as critical habitat was quantified. 

In addition, the area within each Corridor Alternative’s study area (500 feet to each side of the 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-82 September 2016

corridor centerline) and within the Etowah Aquatic Habitat Conservation Plan (Priority 1 and 2 areas 

only) was quantified (USFWS 2007).

Agency Coordination

In August 2007 and September 2010, the following organizations were notified about the Project and 

the Corridor Alternatives:

 USFWS in Athens, Georgia and Cookeville, Tennessee; 

 Tennessee Department of Environment & Conservation (TDEC); 

 GDNR Natural Heritage Program; and 

 US Department of Agricultural Natural Resources Conservation Service (USDA NRCS) in 

Tennessee and Georgia.

3.10.3 Affected Environment

The Project Area spans three major (Level III) ecoregions - the Piedmont, Blue Ridge, and Ridge 

and Valley regions. USEPA defines an ecoregion as an area of similarity regarding patterns in the 

mosaic of abiotic and biotic, aquatic and terrestrial ecosystem components, including geology,

physiography, vegetation, climate, soils, hydrology, land use, and wildlife, with human beings 

considered as part of the biota. They are shown in Figure 3-26.

The Piedmont includes Clayton, Fulton and Cobb Counties, southern Cherokee County, and a small 

area of southeast Bartow County. The Piedmont is the non-mountainous area of the Appalachian 

Highlands, consisting of plains and hills that are a transition between the coastal plain and 

Appalachians. 

The Blue Ridge extends from Georgia northeast to Pennsylvania and consists of ridges, plateaus, 

and mountain peaks that are primarily forested slopes. It is one of the richest areas of biodiversity in 

the eastern United States. Northern Cherokee County and the eastern portions of Bartow, Gordon, 

and Murray Counties are located within this ecoregion. 

The Ridge and Valley region is relatively low-lying but consists of roughly parallel ridges and valleys, 

and is approximately 50 percent forested. It is a transition area between the Blue Ridge and 

Southwestern Appalachians. All of Hamilton, Tennessee, and Catoosa, Whitfield, and Floyd 

Counties, as well as the majority of Bartow, Murray, and Gordon, in Georgia are in the Ridge and 

Valley ecoregion.

Preliminary data indicates that suitable habitat potentially occurs within the Project Area counties for 

177 protected species that are federally listed and/or listed by the states of Georgia or Tennessee. 

The protected species are listed by county in Table 3-25. Inclusion in the list does not necessarily 

mean that the threatened or endangered species is found within the Project Area or within a Corridor 

Alternative. Rather, the list identifies the presence of suitable habitat for a given threatened or 

endangered species within a county as compiled in April 2014 from reports by the USFWS, iPaC 

(Information, Planning and Conservation System); Tennessee Department of Environment and 

Conservation (TDEC); Interactive Rare Species Database for Environmental Review; and GDNR, 

Rare Species and Natural Communities Data. 

Critical habitat is the specific area occupied by a protected species at the time it is listed as a 

protected species on which are found the physical or biological features that are essential to the 

conservation of the species. Critical habitat in the Project Area is shown in Figure 3-27.
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-83 September 2016

Figure 3-26: Ecoregions in Georgia

Source: GDNR website: http://www1.gadnr.org/cwcs/PDF/ga_eco_l3_pg.pdf. 2001
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-84 September 2016

Table 3-25: Threatened and Endangered Species Habitat by County

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

MAMMALS

Corynorhinus rafinesquii

Rafineque’s big-eared 

bat

– Rare Murray   

Myotis grisescens

Gray bat Endangered Endangered

Bartow, Catoosa, 

Cherokee, Floyd, 

Murray, Whitfield

  

Myotis septentrionalis

Northern Long-Eared Bat Threatened –

Bartow, Catoosa, 

Cherokee, Cobb, Floyd,, 

Gordon, Hamilton, 

Murray, Whitfield

  

Myotis sodalis

Indiana bat Endangered Endangered

Bartow, Catoosa, 

Cherokee, Floyd, 

Hamilton, Murray, 

Whitfield

  

BIRDS

Aimophila aestivalis

Bachman’s sparrow –

Rare (GA); 

Endangered 

(TN)

Fulton, Floyd, Hamilton   

Ammodramus henslowii

Henslow’s sparrow – Rare Cobb, Fulton   

Falco peregrinus

Peregrine falcon –

Rare (GA); 

Endangered 

(TN)

Cherokee, Murray   

Haliaeetus leucocephalus

Bald eagle – Threatened Hamilton   

Thryomanes bewicki

Bewick’s wren – Endangered Fulton, Floyd, Hamilton   

INVERTEBRATES, CLAMS

Cyprogenia stegaria

Fanshell Endangered – Hamilton   

Dromus dromas

Dromedary pearlymussel Endangered Endangered Hamilton   

Elliptio arctata

Delicate spike – Endangered Cobb, Fulton   

Elliptio arca

Alabama spike – Endangered Gordon, Floyd, Murray, Whitfield   

Eliptoideus sloatianus

Purple bankclimber 

Threatened Threatened Clayton, Fulton   

Epioblasma florentina 

walkeri

Tan riffleshell 

Endangered – Hamilton   

Epioblasma metastriata

Upland combshell Endangered Endangered Gordon, Murray, 

Whitfield   

Epioblasma 

othcaloogensis Southern 

acornshell

Endangered Endangered Gordon, Murray, 

Whitfield   

Lampsilis abrupta

Pink mucket Endangered Endangered Hamilton   

Hamiota altilis Finelined 

pocketbook Threatened Threatened

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-85 September 2016

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

Hamiota subangulata

Shinyrayed pocketbook Endangered Endangered Clayton, Fulton   

Leptoxis foreman

Interrupted Rocksnail Endangered Endangered Bartow, Floyd, Gordon, Whitfield   

Medionidus acutissimus

Alabama moccasinshell Threatened Threatened

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  

Medionidus parvulus

Coosa moccasinshell Endangered Endangered Bartow, Floyd, Gordon, Murray, Whitfield   

Medionidus penicillatus

Gulf moccasinshell Endangered Endangered Clayton, Fulton   

Plethobasus cooperianus

Orangefoot pimpleback Endangered Endangered Hamilton   

Pleurobema decisum

Southern clubshell 

Endangered Endangered

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  

Pleurobema georgianum

Southern pigtoe Endangered Endangered

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  

Pleurobema hanleyianum

Georgia pigtoe 

Endangered Endangered Gordon, Murray, 

Whitfield   

Pleurobema plenum

Rough pigtoe Endangered Endangered

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  

Pleurobema pyriforme

Oval pigtoe Endangered Endangered Clayton, Fulton   

Pleuronaia dolabelloides

Slabside pearly mussel Endangered – Hamilton   

Ptychobranchus 

foremaniaus

Rayed kidneyshell or 

Triangular Kidneyshell

Endangered Endangered Gordon, Hamilton, 

Murray, Whitfield   

Quadrula intermedia

Cumberland monkeyface Endangered Endangered Hamilton   

Strophitus 

connasaugaensis

Alabama creekmussel

– Endangered Gordon, Murray, 

Whitfield   

Villosa trabalis

Cumberland bean Endangered – Hamilton   

FISH

Chrosomus saylori

Laurel dace Endangered – Hamilton   

Cyprinella caerulea

Blue shiner Threatened Endangered Murray, Whitfield   

Cyprinella callitaenia

Bluestripe shiner – Rare Fulton   

Etheostoma brevirostrum

Holiday darter – Endangered Murray, Whitfield   

Etheostoma ditrema

Coldwater darter – Endangered Bartow, Floyd, Gordon, 

Murray, Whitfield   

Etheostoma duryi

Blackside snubnose 

darter 

– Rare Catoosa   
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-86 September 2016

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

Etheostoma etowhae

Etowah darter Endangered Threatened Bartow, Cherokee,

Floyd, Fulton   

Etheostoma rupestre

Rock darter – Endangered

Bartow, Cherokee, 

Gordon, Murray, 

Whitfield

  

Etheostoma scotti

Cherokee darter Threatened Threatened Bartow, Cherokee, 

Cobb, Floyd, Fulton   

Etheostoma trisella

Trispot darter – Endangered Floyd, Gordon, Murray, Whitfield   

Hemitremia flammea

Flame chub – Endangered Catoosa, Whitfield   

Hybopsis lineapunctata

Lined chub – Rare

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  

Ichtyomyzon bdellium

Ohio lamprey – Rare Catoosa   

Macrhybopsis sp.1

Coosa chub – Endangered

Bartow, Cherokee, 

Gordon, Murray, 

Whitfield

  

Moxostoma carinatum

River redhorse – Rare Floyd, Gordon, Murray, Whitfield   

Notropis ariommus

Popeye shiner – Endangered Catoosa   

Notropis asperifrons

Burrhead shiner – Threatened Murray, Whitfield   

Notropis hypsilepis

Highscale shiner – Rare Clayton, Cobb, Fulton   

Noturus eleutherus

Mountain madtom – Endangered Catoosa   

Noturus undescribed 

Freckleberry madtom – Endangered Cherokee, Murray, Whitfield   

Percina antesella

Amber darter Endangered Endangered

Bartow, Cherokee,

Floyd, Gordon, Murray, 

Whitfield

  

Percina aurolineata

Goldline darter Threatened Threatened Gordon, Murray   

Percina crypta

Halloween darter – Threatened Clayton   

Percina jenkinsi

Conasauga logperch Endangered Endangered Murray, Whitfield   

Percina kusha

Bridled darter – Endangered Cherokee, Gordon, Murray, Whitfield   

Percina lenticula

Freckled darter – Endangered Catoosa, Whitfield   

Percina sciera

Dusky darter – Rare Murray   

Percina shumardi

River darter – Endangered Catoosa, Hamilton 

Percina tanasi

Snail darter Threatened Threatened Catoosa, Hamilton   
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-87 September 2016

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

Phenacobius uranops

Stargazing minnow – Threatened

Bartow, Cherokee, 

Gordon, Murray, 

Whitfield

  

REPTILES, AMPHIBIANS

Crytobranchus 

alleganiensis

Eastern hellbender 

– Threatened Catoosa   

Graptemys geographica

Map turtle – Rare Floyd, Gordon, Murray, Whitfield   

Graptemys pulchra

Alabama map turtle – Rare Floyd, Gordon, Hamilton, Murray, Whitfield   

Gyrinophilus palleucus

Tennessee cave 

salamander 

– Threatened Catoosa   

CRAYFISH

Cambarus cymatilis

Conasauga blue 

burrower 

– Endangered Murray 

Cambarus extraneus

Chickamauga crayfish – Threatened Catoosa, Hamilton   

Cambarus fasciatus

Etowah Crayfish – Threatened Bartow, Cherokee   

Cambarus howardi

Chatahoochee crayfish – Threatened Cobb, Fulton   

Cambarus speciousus

Beautiful crayfish – Endangered Murray



Gomphus consanguis

Cherokee clubtail – Threatened Catoosa, Hamilton   

Ophiogomphus edmundo

Edmund’s snaketail – Endangered Bartow, Cherokee 

PLANTS

Alnus maritime

Seaside alder – Threatened Bartow   

Arabis georgiana

Georgia rockcress Threatened Threatened Floyd   

Asclepias purpurascens

Purple milkweed – Rare Floyd 

Aureolaria patula

Yellow foxglove – Threatened Bartow 

Berberis Canadensis

American barberry – Endangered Floyd, Hamilton   

Carya myristiciformus

Nutmeg hickory – Rare Hamilton 

Clematis fremonti

Fremont’s leather flower – Endangered Floyd   

Clematis glaucophyllia

White-leaved 

leatherflower 

– Endangered Murray   

Clematis socialis

Alabama leather flower Endangered Endangered Bartow, Floyd 

Coreopsis latifolia

Broadleaf tickseed – Rare Clayton, Cobb, Fulton, Murray



Crataegus triflora

Three-flowered Hawthorn – Threatened Fulton, Murray   
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-88 September 2016

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

Cyrpipedium acaule

Pink lady’s-slipper – Unusual

Bartow, Cherokee, 

Floyd, Gordon, Murray, 

Whitfield

  

Cypripedium parviflorum

Yellow ladyslipper – Rare

Cherokee, Floyd, 

Hamilton, Murray, 

Whitfield

  

Cypripedium parviflorum

Golden slipper – Rare Hamilton   

Delphinium exaltatum

Tall larkspur – Endangered Hamilton   

Diamopha smallii

Small’s stonecrop – Endangered Hamilton   

Diervilla lonicera

Northern bushhoneysuckle – Threatened Catoosa, Murray   

Diervilla sessilifolia

Mountain bushhoneysuckle – Threatened Hamilton   

Draba aprica

Sun-loving draba – Endangered Floyd   

Gratiola floridana

Florida hedge-hyssop – Endangered Hamilton   

Helianthus verticillatus

Whorled sunflower Endangered

Candidate(TN)

Endangered 

(GA)

Hamilton, Floyd 

Hydrastis canadensis

Goldenseal – Endangered Floyd   

Isoetes melanospora

Black-Spored quillwort Endangered – Hamilton   

Isotria medeoloides

Small whorled pogonia Threatened Endangered , Hamilton   

Jamesianthus 

alabamensis

Alabama warbonnet 

– Endangered Floyd 

Lejeunea sharpie

Sharp’s lejeunea – Endangered Cherokee, Cobb, Fulton, Hamilton

  

Lilium canadense

Canada Lily – Threatened Floyd   

Lilium michiganense

Michigan lily – Rare Floyd 

Lilium philadelphicum

Wood lily – Endangered Bartow, Cobb, Hamilton   

Lonicera flava

Yellow honeysuckle – Threatened Hamilton   

Lysimachia fraseri

Fraser’s loosestrife –

Rare (GA); 

Endangered 

(TN)

Floyd   

Marshallia mohrii Mohr’s 

Barbara button Threatened Threatened Floyd 

Monotropsis odorata

Sweet pinesnap – Threatened Floyd, Hamilton   

Nestronia umbellule

Indian olive –

Rare (GA); 

Endangered 

(TN)

Floyd, Hamilton   

Neviusia alabamansis

Alabama snow wreath – Threatened Bartow, Floyd 
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-89 September 2016

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

Pachsyandra 

procumbens

Allegheny spurge 

– Rare Bartow, Floyd 

Platantherea intergrilabia

White fringeless orchid or 

Monkeyface orchid 

Threatened

Threatened 

(GA), 

Endangered

(TN)

Floyd, Hamilton   

Phemeranthus mengesii

Menge’s fame-flower – Threatened Hamilton   

Prenanthes barbata

Barbed rattlesnake root – Threatened Fulton, Murray 

Rhus michauxii

Dwarf sumac or 

Michaux’s sumac

Endangered Endangered Cobb   

Ribes curvatum

Granite gooseberry – Threatened Hamilton   

Rudbeckia heliopsidis

Little river black-eyed 

Susan 

– Threatened Bartow, Floyd, Hamilton,   

Sabatia capitata

Cumberland rose gentian –

Rare (GA); 

Endangered 

(TN)

Hamilton   

Schisandra glabra

Bay star-vine – Threatened Bartow, Cobb, Hamilton,   

Scutellaria montana

Large-flowered skullcap Threatened Threatened Cobb   

Silene regia

Royal catchfly – Endangered Floyd, Hamilton 

Siliphium pinnatifidum

Southern prarie-dock – Threatened Catoosa, Murray   

Spiraea virginiana

Virginia spiraea Threatened Endangered Hamilton   

Sylisma humistrata

Southern morningglory – Threatened Hamilton   

Symphyotrichum 

georgianum

Georgia aster 

– Threatened

Bartow, Cobb, 

Cherokee, Floyd, Fulton, 

Murray, Whitfield, 

Gordon

  

Thalictrum debile

Trailing meadowrue – Threatened Floyd, Gordon, Hamilton   

Thaspium pinnatifidum

Glade meadow-parsnip – Endangered Floyd   

Trientalis borealis

Starflower – Endangered Cherokee, Clayton, Cobb, Fulton 

Trillium lancifolium

Narrow-leaved trillium –

Endangered Hamilton   

Trillium pusillum

Dwarf trillium – Endangered Bartow, Floyd 

Trillium rugelii

Southern nodding trillium – Endangered Floyd, Gordon, Murray, Hamilton

  
Chapter 3 Affected Environment and Environmental Consequences

Atlanta-Chattanooga HSGT Tier 1 DEIS 3-90 September 2016

Scientific Name

Common Name

Federal

Status State Status1 County/Counties

I-75 

Corridor

East 

Corridor

I-75/ 

Rome 

Corridor

Viburnum bracteatum

Limerock arrow-wood – Endangered Bartow, Cherokee, Cobb, Fulton 

Waldsteinia lobata

Barren strawberry – Rare

Bartow, Catoosa, Floyd, 

Gordon, Hamilton, 

Murray, Whitfield

  

Xerophyllum 

asphodeloides

Eastern turkeybeard 

– Rare Hamilton   

Xyris tennesseensis

Tennessee yellow-eyed 

grass 

Endangered Endangered Bartow, Hamilton   

Sources: USFWS, iPaC; TDEC, Interactive Rare Species Database for Environmental Review; GDNR, Rare Species and Natural 

Communities Data 2014

Notes: 1State Status listed for each species applies to the applicable state or both TN and GA, unless the difference is specifically 

noted

– = Species does not have protected designation at the federal or state level.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-91 September 2016

Figure 3-27: Critical Habitats

Sources: USFWS, iPaC; TDEC, Interactive Rare Species Database for Environmental Review; GDNR, Rare Species and Natural 

Communities Data 2014
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-92 September 2016

The Corridor Alternatives pass through nine general habitat types. Each is described below. The 

Etowah Aquatic Habitat Conservation Plan (Etowah HCP), although not formally adopted, provides 

guidance for the protection of water quality and 10 imperiled aquatic species that live in the Etowah 

Watershed. The watershed is traversed by each Corridor Alternative in Bartow, Cherokee, and Cobb 

Counties and is traversed by I-75/Rome Corridor Alternative in Floyd County. The species include 

three federally listed fish species: Etowah darter (endangered), amber darter (endangered), and 

Cherokee darter (threatened). Under the Etowah HCP, local governments would be able to pass 

ordinances and policies to ensure that development activities do not cause harm to these fish 

species. In return, developers would enjoy reduced consultation times with USFWS, saving them 

money. Also, the local governments would receive an Incidental Take Statement, which would give 

them, and the developers who adhere to the regulations, protection from prosecution if fish are 

accidentally killed. This ability would streamline and limit the coordination required of the developers 

with the USFWS, and would limit prosecution for incidental impacts. The nine general habitat types 

are:

 High intensity urban - multi-family dwellings, commercial/industrial, prisons, speedways, 

junkyards, confined animal operations, roads, railroads, airports, runways, and utility swaths.

 Low intensity urban - Single-family dwellings, recreation, cemeteries, playing fields, campus-like 

institutions, parks, and schools. 

 Deciduous forest - Forest composed of at least 75 percent deciduous trees in the canopy, and 

deciduous woodland. Twelve such areas, characterized by large contiguous tracts of forest land 

at least 100 acres in size, were identified as potential migratory bird habitats along the proposed 

alternatives. 

 Evergreen forest - Evergreen forest, at least 75 percent evergreen trees, managed pine 

plantations, and evergreen woodland.

 Clearcut and sparse - recent clearcuts, sparse vegetation, and other early successional areas.

 Open water - Lakes, rivers, ponds, ocean, industrial water, aquaculture that contained water at 

the time of image acquisition.

 Row crop/pasture - Row crops, orchards, vineyards, groves, horticultural businesses, pasture, 

and non-tilled grasses.

 Forested wetland - Cypress gum, evergreen wetland, deciduous wetland, depressional wetlands, 

and shrub wetlands.

 Quarries/strip mines and rock outcrops - exposed rock and soil from industrial uses, gravel pits, 

landfills, rock outcrops, mountaintops, and barren land.

The vast majority of the Project Area falls into the high intensity urban and low intensity urban habitat 

type, while deciduous and evergreen forest are the next most common types. Other habitats 

mentioned above are encountered sporadically within each Corridor Alternative.

3.10.4 Environmental Consequences

3.10.4.1 No-Build Alternative

The No-Build Alternative assumes an HSGT system would not be built between Atlanta and 

Chattanooga. Passenger service between the two cities would consist of existing bus services, air 

travel, and continued automobile use along I-75, US 411, and US 41. In the No-Build Alternative, the 

impacts to biological resources could potentially occur if additional ROW is needed. As the 

geographic scope and nature of the No-Build Alternative projects is limited, the potential effects of 

the projects are likely to be limited to the area in which the projects are constructed. The potential for 

impacts to biological resources would be determined through the environmental processes for the 

already planned transportation improvements.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-93 September 2016

3.10.4.2 Corridor Alternatives

Within each of the Corridor Alternatives, the potential for direct impacts to protected species and 

their habitat will depend on the location of those species and habitat and the ability of GDOT and 

TDOT to refine the selected alternative to avoid or minimize impacts. Species and habitat in the 

vicinity of proposed station locations may be vulnerable to impacts resulting from land use changes 

that could be induced by the Project indirectly.

Table 3-26 shows the number and total acreage of threatened and endangered species habitats 

within the Corridor Alternatives. The I-75 and I-75/Rome Corridor Alternatives have the least 

potential to impact threatened and endangered species habitat; the East Corridor Alternative has the 

highest potential. 

Table 3-26: Threatened and Endangered Species Habitats 

Corridor

Alternative

Number of Threatened 

and Endangered 

Species Habitats

Acres of Threatened 

and Endangered 

Species Habitat

I-75 21 1,907

East 38 2,158

I-75/Rome 21 1,817

Sources: USFWS in Athens, Georgia and Cookeville, Tennessee 2010; TDEC 

2010; GDNR Natural Heritage Program 2010; and USDA Natural Resources 

Conservation Service in Tennessee and Georgia 2010

3.10.5 Potential Mitigation

GDOT and TDOT will examine appropriate and practicable steps to reduce the potential effects of 

the Project on threatened and critical habitats. These steps will be implemented through design 

refinements in consultation with state and federal agencies as appropriate. Minimization will typically 

focus on decreasing the footprint of the Project in and near these critical habitats and alignment

shifts to avoid populations and/or habitat areas.

Potential mitigation and minimization strategies could include but are not limited to restricting 

construction activities during time of year that is sensitive to species (i.e., breeding, nesting, 

migration). Although the location of the proposed alignment along existing transportation corridors 

would minimize the additional impact to natural/undeveloped areas, there would still be potential for 

cumulative impacts. Additionally, some bird and bat species roost in transportation infrastructure 

(such as under bridges); therefore, mitigation strategies such as relocation or installation of new 

habitats of roosting areas within the existing transportation corridors would also be considered. 

Affected plants and trees could also be relocated. Furthermore, conservation banking and in-lieu fee 

or in-kind mitigation could be used for unavoidable impacts to listed species and their habitats.

3.10.6 Subsequent Analysis

If a Corridor Alternative is selected, the Tier 2 NEPA process will further evaluate the potential 

effects of the selected alternative on biological resources. The analysis will include a detailed field 

survey to determine the presence of federally and state-protected species in the selected alternative 

corridor, a spatial evaluation of both plant and animal species within the selected alternative corridor, 

as well as the identification of potential conflict areas. The USFWS has noted records of critical 

habitat within and along both the Rome/I-75 and the East Corridors. These habitats should be 

avoided in Tier 2.

Additional detailed field survey, including vegetation surveys, will be undertaken by GDOT and 

TDOT to determine the presence of populations and/or habitat for federally protected and state-listed 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-94 September 2016

species. For example, portions of each Corridor Alternative travel through high priority waters, 

shown in Figure 3-25, and identified and updated by GDNR in 2015. These watersheds have been

identified as high priority based on the number of high priority aquatic species populations present in 

the watershed and the rarity of those species. There are also rivers in the region that are cold water 

and listed as trout streams. These sensitive water resources host listed or at-risk aquatic as well as 

a food-base for listed bats within the area. Habitat quality will also be considered. Activities within 

sensitive watersheds will require review and approval by the USFWS. 

In addition, data sources used to determine habitat for protected species habitat in this Tier 1 EIS 

predated the range expansion for federally protected bats species. Impacts to suitable habitat for 

federally protected bats (e.g., caves or cave-like structures, bridges, culverts) and impacts to bats 

due to construction activities will be assessed in the Tier 2 NEPA. 

The Tier 2 NEPA process will also consider impacts specific to construction type (at-grade, aerial, 

tunnel) and fragmentation of habitat for species of concern, and will identify specific mitigation 

strategies to address remaining impacts on biological resources.

3.11 Secondary and Cumulative Effects

This chapter presents a preliminary evaluation of the potential secondary (or indirect) effects and 

cumulative (incremental) effects of the Project. This Tier 1 evaluation presents a generalized 

assessment of the potential secondary and cumulative effects based on Tier 1 concepts that would 

be further refined in the Tier 2 NEPA phase, once the scope and timing of improvement projects are 

better defined.

3.11.1 Legal and Regulatory Context

Secondary Effects

The CEQ NEPA regulations and FRA’s Procedures require that there be an analysis of potential 

secondary effects for federally funded projects.15 The CEQ implementing regulations require that an 

EIS include a discussion of preliminary environmental consequences, including “indirect effects and 

their significance” (40 CFR 1502.16). In addressing potential uncertainties in this type of analysis, 

the CEQ regulations require the EIS to make a “good faith effort” to identify and disclose indirect or 

secondary effects (CEQ 1981).

Cumulative Effects

The CEQ/NEPA regulations and FRA Procedures also require that an analysis of potential 

cumulative effects take place for federally funded projects. The CEQ/NEPA implementing 

regulations require that an EIS include a discussion of preliminary environmental consequences. 

According to 40 CFR 1508.7, this includes “the impact on the environment, which results from the 

incremental impact of the action when added to other past, present, and reasonably foreseeable 

future actions, regardless of what agency (federal or non-federal) or person undertakes such other 

actions”. In addressing potential uncertainties in this type of analysis, CEQ requires the EIS to make 

a “good faith effort” to identify and disclose cumulative effects (CEQ 1981).

3.11.2 Methodology

Secondary Effects

CEQ defines secondary effects as “impacts which are caused by the action and are later in time or 

farther removed in distance, but are still reasonably foreseeable.” Secondary effects could include 

 

15 FRA’s Procedures note these as “indirect” impacts (64 FR 28554).
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-95 September 2016

growth-inducing impacts and other impacts related to changes in the pattern of land use, population 

density or growth rate, and related impacts on air and water and on other natural systems, including 

ecosystems” (40 CFR 1508.8(b)). An example of a secondary effect is a new HSGT station built in 

an undeveloped area and commercial and residential uses, which otherwise would not have been 

built, develop in the station area. However, the provision of HSGT does not in and of itself cause 

secondary development to occur.

Secondary effects typically include impacts to human and natural systems from changes in land use 

patterns and growth induced by proposed public and private development plans. Assessing the 

potential secondary effects involves defining the scope and geographical boundaries for the 

analysis. The Project Team analyzed the potential secondary effects on a broad scale due to the 

general nature of the Project description. Consideration of local area secondary effects takes place 

as part of subsequent analysis following greater definition of the alignment and station areas, 

construction footprints, and the amount of right-of-way needed.

Cumulative Effects

Cumulative effects are changes to the environment brought about by an action in combination with 

other past, present and future human actions. In simplest terms, analyzing cumulative effects means 

considering and accounting for the impacts of a proposed action in the context of the existing 

transportation system and improvements to it that are reasonably foreseeable in the vicinity. FRA 

defines “reasonably foreseeable” as projects that are both planned and funded.

This Tier 1 DEIS analyzes the potential cumulative effects of the proposed Project on a broad scale 

and at a conceptual level. The purpose of this analysis is to identify the potential cumulative effects 

of the Corridor Alternatives in combination with other major improvements in the Project Area. The 

results presented here are qualitative. The Project Sponsor will consider the site-specific cumulative 

effects of the Preferred Corridor Alternative at a more detailed level, including development effects, 

as part of the subsequent Tier 2 analysis.

Improvement projects included in the cumulative effects analysis are transportation projects in or 

near the Project Area approved for implementation under the No-Build Alternative. The project list 

focuses on those that, when combined with the Atlanta to Chattanooga HSGT Project, could 

contribute to cumulative effects. Section 2.3.1 lists the projects. This analysis only considered

transportation improvement projects. Land developments of regional impact would be included 

during subsequent Tier 2 analysis of secondary and cumulative effects.

3.11.3 Potential for Secondary and Cumulative Effects

The potential for secondary and cumulative effects exists for all Corridor Alternatives under 

consideration. The effects associated with the Corridor Alternatives would primarily be attributable to 

transportation and development projects and secondary development that may occur at station 

areas. For the purposes of the impact analyses presented in this EIS, potential station locations 

were identified along each corridor and placed in the vicinity of major points of interest, clusters of 

population and employment centers, and locations easily accessible by other modes of transit (such 

as an airport, city centers, or major interstate highways). Station location choices were also based 

upon the results of scoping and extensive coordination with local city and county officials. Station 

locations were preliminary and conceptual in nature at this point in the process. Station 

configurations and layouts will be refined to a greater level of precision during future analysis.

At this level of analysis, the results for secondary and cumulative effects would essentially be the 

same for all Corridor Alternatives considered. More in-depth evaluations of these topic areas will 

take place during subsequent analysis in the Tier 2 NEPA phase, following the selection of a Build 

Alternative and determination of locations for proposed facilities.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-96 September 2016

3.11.3.1 No-Build Alternative

Under the No-Build Alternative, implementation of the proposed HSGT Project would not happen, 

therefore, no new secondary or cumulative effects would occur beyond those attributed to other 

projects. The No-Build Alternative would not provide the improved level and quality of HSGT service

between Atlanta and Chattanooga. The primary transportation mode between these cities would 

continue to be automobile travel. The anticipated result would be increased traffic congestion, 

additional automobile crashes, and increases in vehicular pollutant emissions, and the associated 

degradation of air quality associated with congested roadways.

3.11.3.2 Corridor Alternatives

Secondary Effects

A Corridor Alternative would result in secondary effects some time after the Project is built, or some 

distance from the location of the Project. Secondary effects attributable to the Atlanta to 

Chattanooga HSGT Project would result mainly due to the new HSGT transportation system 

accessibility provided at the proposed station areas. This would be due to residential and 

commercial development potentially induced by the Project that could occur on undeveloped land 

within a three-to-five-mile radius of access points to the proposed service. The proposed stations 

would serve as those access points. Implementing HSGT within a corridor does not, in and of itself, 

cause secondary development to occur. Typically, local jurisdictions via their land use plans may 

allow more intense land development to occur around such transportation improvements, however 

development may occur regardless of new HSGT station construction. More precise station location

decisions would result via coordinated efforts with local city and county elected officials and planners 

to help ensure that the sites and opportunities presented for growth development are suitable to 

handle increased traffic and other demands.

Table 3-27 presents the potential positive and negative secondary effects of the Corridor 

Alternatives. The table includes those resource areas where impacts are most likely to occur. It is 

important to note that the corridor alternatives presented in this Tier 1 DEIS are not precisely defined 

alignments, and that the route for the selected alternative would be further refined during subsequent 

analysis. Thus, potential secondary effects presented here are overviews of likely impacts expected 

along the three Corridor Alternatives. Actual secondary effects may be greater or lesser, which will 

be determined following the selection of a corridor alternative and precise alignment definition.

Table 3-27: Potential Secondary Effects of the Corridor Alternatives

Resource Potential Secondary Effect

Transportation

 Increased traffic from potential induced development around station locations

 Bus routes modifications to accommodate changes in traffic patterns resulting from 

the locations of stations

Air Quality  Localized air quality impacts from increased traffic due to potential induced 

development

Noise  Noise impacts from increased traffic due to potential induced land development

Socioeconomics 

and Economic 

Development

 Population and employment increases due to potential induced development

 Potential positive effect on business sales and revenues 

 Economic development around HSGT stations, with increased employment 

opportunities and increased tax revenues

Communities and 

Environmental 

Justice

 Effects on communities due to change in development and property values, and 

associated traffic impacts due to induced development 

 Increased need for educational, health care, and recreational facilities due to 

potential induced development

Parklands, 

Wildlife Refuges, 

Recreation Areas

 Potential wildlife habitat impacts from induced development

 Potential noise and visual effects
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-97 September 2016

Cultural 

Resources

 Induced development may have the potential to affect cultural resources although 

any impacts would likely be required to be mitigated, including potential provision of 

historic mitigation 

 Potential noise and visual effects

Water Resources

 Indirect effects on surface waters, aquifers, wetlands, and floodplains due to 

induced development, although the extent of the conversion would depend on the 

siting and location of development and regulatory mechanism to minimize/mitigate 

any fills

Biological 

Resources

 Potential wildlife habitat effects from induced development. The extent of this effect 

is dependent on the siting, location, and nature of the development and measures 

to minimize/mitigation any effects

Cumulative Effects

A general description of the potential types of cumulative effects on resources is in Table 3-28. The 

effects summarized in Table 3-28 would apply to all Corridor Alternatives.

3.11.3.3 Potential Mitigation Measures

As described above, implementation of any of the Corridor Alternatives, when considered in the 

context of implementation of other transportation projects, may have effects on air quality, cultural 

resources, land cover, water and biological resources, and transportation. For many of the negative 

effects identified, mitigation measures could minimize the overall indirect and cumulative effects. 

Mitigation strategies will be considered in the Tier 2 NEPA phase. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 3-98 September 2016

Table 3-28: Potential Cumulative Effects of the Corridor Alternatives

Resource Potential Cumulative Effect

Transportation

 Potential cumulative traffic impacts that could create congestion on surface streets 

leading to and from proposed stations, which would be more pronounced at proposed 

station locations in downtown Atlanta and Chattanooga

 Project would contribute to a better overall transportation network that would function to 

more effectively and efficiently meet the needs of commuters, travelers, residents, and 

businesses within the Project Area 

 Potential to change how people travel across the Project Area, reducing the share of 

trips by automobile, air, and intercity bus modes as travelers switch to HSGT service

Air Quality

 Potential positive impacts on regional air quality by contributing to the development of a 

more complete multi-modal transportation system within the Project Area and 

encouraging changes in long-term travel behavior by attracting riders away from longdistance auto and short-term air travel, as well as through the advocacy for more energy 

efficient modes of transport that improve air quality

Noise  Localized cumulative noise impacts could occur at station locations primarily in urban 

areas with higher densities of sensitive receptors

Socioeconomics and 

Economic 

Development

 Population and employment around the proposed station locations may increase above 

the current projections. This would influence the density, employment mix, design and 

timing of commercial development 

 Potential also exists for housing needs to increase to accommodate the likely increases 

in population and employment

Communities and 

Environmental Justice

 Potential cumulative effects related to quality of life, which could include noise and 

vibration impacts, barrier effects, aesthetics, and safety

 Benefit from improved mobility options provided by all transportation projects under 

construction or planned within the Project Area

Parklands, Wildlife 

Refuges, and 

Recreation Areas

 Potential cumulative impacts could include proximity effects, such as noise impacts, on 

the resource

Cultural Resources  Potential cumulative effects would be primarily due to increased noise and vibration as 

a result of new HSGT service

Water Resources  Possible cumulative effects due to increased impervious ground surfaces, stormwater 

run-off and water quality

Biological Resources  Possible cumulative effects due to land use conversion resulting in habitat loss

3.11.3.4 Subsequent Analysis

Subsequent Tier 2 analysis will further evaluate the potential for secondary land development and 

cumulative effects on resources (e.g., parklands, cultural resources, water and biological resources) 

within the project study area. The Project Sponsor will reevaluate the potential secondary effects of 

the Project in the context of current market forces, and existing and proposed developments near 

the stations. The analysis would also define the specific cumulative effects the Project may have on 

key resources when considered with other past, present, and future actions. Coordination with state 

and federal resource agencies and metropolitan planning organizations would provide more specific 

information about local projects for consideration.
Chapter 4 Preliminary Section 4(f) Evaluation

Atlanta-Chattanooga HSGT Tier 1 DEIS 4-1 September 2016

4.0 PRELIMINARY SECTION 4(F) EVALUATION

This preliminary Section 4(f) Evaluation has been prepared to comply with the US Department of 

Transportation (USDOT) Act of 1966 (49 USC § 303), hereinafter referred to as "Section 4(f)," and 

FRA’s Procedures. Additional guidance was taken from the Federal Highway Administration’s 

(FHWA) implementing regulations (23 CFR Part 774).

4.1 Summary Statement

The preliminary Section 4(f) Evaluation describes the potentially affected properties identified in 

Sections 3.7 and 3.8 of the Tier 1 DEIS that are protected under Section 4(f) of the U.S. Department 

of Transportation Act of 1966, as amended, and documents whether those potential impacts have a 

bearing on the decision to be made in the Tier 1 FEIS/ROD. Specifically, the Project could result in a 

Section 4(f) use of one or more properties. FRA will make determinations of use during Tier 2 

analysis if a specific alignment(s) is identified and refined within the wide, selected Tier 1 buffer area. 

The identified potential uses do not have a bearing on the decision to be made in the Tier 1 

FEIS/ROD because they are not definitive in this preliminary evaluation. Each corridor provides the 

opportunity during Tier 2 for FRA, GDOT, and TDOT to examine a full range of specific, project level 

alignment alternatives within the selected corridor, including avoidance alternatives as required to 

satisfy Section 4(f). The tiered approach allows FRA not to preclude the ability to identify, evaluate 

and ultimately select a specific alignment for the HSGT project that satisfies Section 4(f) in addition 

to NEPA. The wide buffer areas used in Tier 1 give FRA, GDOT, and TDOT the flexibility to 

determine and refine one or more alignments within the selected buffer area, and to avoid or 

minimize impacts and uses of resources including Section 4(f) properties during Tier 2. Opportunities 

to minimize harm to Section 4(f) properties in Tier 2 are not precluded by Tier 1 decision-making.

4.2 Methodology

For purposes of this preliminary evaluation, the properties identified in this chapter are within a 

1,000-foot wide buffer along each Corridor Alternative. For this Tier 1 DEIS, the Corridor Alternatives 

are examined within corridors 1,000 feet in width, which allows for variation in the horizontal 

alignments to be determined during the Tier 2 NEPA phase and is sufficiently wide to evaluate the 

potential environmental issues associated with the alternatives. No alignments have been defined in 

this Tier 1 DEIS. If a Corridor Alternative is selected, the wide buffer areas used in this Tier 1 DEIS 

analysis give FRA, GDOT, and TDOT the flexibility to determine and refine one or more alignments 

within the selected Corridor Alternative, and to avoid or minimize impacts and uses of resources 

including Section 4(f) properties during the Tier 2 phase of the project. For more detail on the 

methodology used to identify these properties, refer to Sections 3.7 and 3.8.

4.3 Legal and Regulatory Context

Section 4(f), as amended, protects public parks and recreational lands, wildlife and waterfowl 

refuges, and properties of national, state, or local significance that have been determined eligible or 

listed in the National Register of Historic Places (NRHP) from use by transportation projects, unless 

there are no prudent and feasible alternatives to their use. The use of such resources can be 

approved by FRA only if there is no feasible and prudent avoidance alternative and only after the

proposed project is determined to have included all possible planning to minimize harm. Section 4(f) 

requires the U.S. DOT to seek concurrence from the U.S. Department of the Interior before making 

these findings.

This preliminary evaluation is consistent with the FHWA implementing regulation (23 CFR 774.7(e))

regarding tiered EIS documents. In a tiered EIS, the detailed information necessary to complete a 

Section 4(f) approval may not be available. In such cases, the potential impacts that a proposed 
Chapter 4 Preliminary Section 4(f) Evaluation

Atlanta-Chattanooga HSGT Tier 1 DEIS 4-2 September 2016

project could have on Section 4(f) properties are identified along with a determination as to whether 

those potential impacts have a bearing on the Tier 1 decision. 

4.4 Affected Environment

4.4.1 Section 4(f) Properties

Table 4-1 presents the number of historic properties, archaeological sites, cemeteries, and public 

parks that may be protected under Section 4(f) within the 1,000-foot buffer of each Corridor

Alternative. They are described further in the following sections and in Sections 3.7 and 3.8 of this 

Tier 1 DEIS.

Table 4-1: Numbers of Section 4(f) Properties with 1,000-foot Buffer of Corridor Alternatives

Corridor 

Alternative 

Historic 

Properties

Archaeological 

Sites Cemeteries Public Parks

I-75 26 32 4 21

East 66 46 3 19

I-75/Rome 33 38 5 25

Sources: NRHP documentation on file with the Tennessee Historical Commission - Tennessee SHPO 2010; Georgia SHPO 

2010; Georgia DNR survey 2010; Coosa Valley Regional Development Center 2010; Northwest Georgia Regional 

Commission 2010; ARC 2010; NAHRGIS database 2010; GHBS 2010; and Regional and local historical societies and county 

planning and zoning departments in Bartow, Catoosa, Cherokee, Clayton, Cobb, Douglas, Floyd, Fulton, Gordon, Hamilton, 

Murray, Paulding, Polk, and Whitfield counties; U.S. Home Town Locator 2010; Google Earth 2010; Georgia DNR 2010

Note: The Historic Properties column includes all historic properties provided by the sources listed above. Further research on 

the cultural resources located in the study area will be conducted in the Tier 2 NEPA process.

4.4.1.1 Historic Sites 

The eligibility of potential historic sites and properties for the NRHP has not been determined in the

Tier 1 DEIS. Sites listed in the NRHP, sites determined eligible for listing in the NRHP, sites 

potentially eligible, and unevaluated sites that have been identified through a literature review are 

listed in Tables 3-18 and 3-19 in Chapter 3. Note that in some cases, a cemetery, after evaluation, 

may be listed on the NRHP as a historic site or as an archaeological site. Cemeteries are listed in 

Table 3-21 of Chapter 3. These tables present all properties identified within a 1,000-foot buffer 

area of the Corridor Alternatives. During the Tier 2 NEPA process, an Intensive Cultural Resources 

Survey will be conducted and the findings will be reviewed through consultation with the SHPO of 

each state, in accordance with Section 106 of the NHPA, to determine the eligibility of all sites that 

have not been previously listed. 

4.4.1.2 Archaeological Sites

Section 4(f) also applies to archaeological sites that are listed or eligible for listing in the NRHP. 

Section 4(f) does not apply to archaeological sites where the value relates to information that can be 

gathered through data recovery or the value is minimal for preservation in place. Additional 

archaeological studies will be conducted in Tier 2 NEPA analysis, including an Intensive Cultural 

Resources Survey and consultation with the SHPO of each state, to fully determine eligibility and 

determine whether sites worthy of preservation need to be preserved in place. Table 3-20 in 

Chapter 3 lists the number of potential archaeological sites and their respective NRHP status in the 

buffer of each Corridor Alternative.

4.4.1.3 Public Parks

Section 3.7 of the Tier 1 DEIS discusses the parks, wildlife refuges, and recreation properties within 

the 1,000-foot buffer areas of the Corridor Alternatives. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 4-3 September 2016

Table 3-17 in Chapter 3 presents the public parks, recreational facilities, and conservation/wildlife 

refuges within the 1,000-foot buffer of each Corridor Alternative.

4.5 Potential Uses of Section 4(f) Properties

Potential “uses” of Section 4(f) properties are defined as follows:

 A permanent use occurs when a transportation project incorporates the resource into the facility 

and includes both fee simple acquisition and permanent easements.

 A temporary adverse use occurs when a transportation project temporarily occupies a portion of 

the resource, which results in an adverse condition. 

 A constructive use or proximity effect occurs when the resource is not taken by right-of-way

(ROW). Proximity effects would compromise the activities or features that qualify the property as 

a Section 4(f) resource. 

FRA, GDOT, and TDOT can determine that certain uses have a de minimis impact on covered 

properties, provided the official with jurisdiction over the property agrees in writing that the impact is 

minor and will not affect the activities, features, or attributes of the property.

If a Corridor Alternative is selected, a Section 4(f) use of one or more properties listed above could 

occur because of the Project. FRA, GDOT, and TDOT will make determinations of use during Tier 2 

analysis when a specific alignment(s) is identified and refined within the wide, selected Tier 1 buffer 

area. The identified potential uses do not have a bearing on the decision to be made in the Tier 1 

FEIS/ROD because the key factors identified in the EIS relate to other issues - ridership, cost, and 

natural resources effects- that would not affect Section 4(f) resources. The wide buffer areas used in 

Tier 1 give FRA, GDOT, and TDOT the flexibility to determine and refine one or more alignments 

within the selected buffer area, and to avoid or minimize impacts and uses of resources including 

Section 4(f) properties during Tier 2.

4.6 Avoidance Analysis, Least Overall Harm Analysis, and All 

Possible Planning to Minimize Harm

The information presented in Table 4-1 shows that the East Corridor Alternative has the highest 

number of cultural resources, while having the fewest number of parks. The I-75 and I-75/Rome 

Corridor Alternatives are generally equivalent with fewer cultural resources in number and a larger 

numbers of parks compared with the East Corridor Alternative.

Because the configuration of an alignment has not been determined at this stage in the development 

of the proposed project, it would be premature to identify specific alternatives to avoid Section 4(f) 

properties because additional data are needed on the Section 4(f) properties and additional design 

detail is needed for the Preferred Corridor Alternative. During the Tier 2 NEPA phase, avoidance of 

uses of these resources would be made possible in many cases through minor redesign or 

narrowing of the disturbance limits. Additional studies and coordination with the SHPOs of Georgia 

and Tennessee, appropriate tribes and other Section 106 consulting parties are needed to determine 

what historic and archaeological resources are eligible for listing in the NRHP and which 

archaeological sites are worthy of preservation in place. Additional research also will be needed to 

confirm the Section 4(f) status of parks, particularly for multiple use lands, or where the ownership 

status is unclear. 

More detailed design is needed to further define both the ROW requirements and the land that would 

be required during project construction. As design is advanced and its effects are studied in a Tier 2 

NEPA document, FRA, GDOT, and TDOT will complete the Section 4(f) evaluation by determining 
Chapter 4 Preliminary Section 4(f) Evaluation

Atlanta-Chattanooga HSGT Tier 1 DEIS 4-4 September 2016

use(s) and applying the following evaluations as appropriate: de minimis impact, prudent and 

feasible avoidance alternative analysis, least overall harm analysis, and all possible planning to 

minimize harm.

4.7 Preliminary Coordination

Early coordination letters were sent to the SHPOs of Georgia and Tennessee to collect information 

on existing cultural resources in the Project Area (see Appendix E). However, coordination as 

required by Section 106 to determine the eligibility of cultural resources and effects of the proposed 

project on those resources has not been undertaken. If a Corridor Alternative is selected, 

coordination with the SHPOs and other officials with jurisdiction will occur during Tier 2 analysis 

when FRA, GDOT, and TDOT will determine and refine one or more alignments within the selected 

Tier 1 Corridor Alternative buffer area, and determine project-related uses of protected properties.

4.8 Preliminary Section 4(f) Approvals and Subsequent Analysis

The following activities will be conducted during Tier 2 NEPA analysis to enable a Section 4(f) 

evaluation to be completed:

 Prepare detailed plans and profiles of the Preferred Corridor Alternative.

 Prepare Phase I Intensive Cultural Resource Surveys and coordinate with Georgia and 

Tennessee SHPOs and other consulting parties to determine resource eligibility for listing in the 

NRHP. These efforts, in accordance with Section 106 of the NHPA, will be used to determine 

whether and where a use of protected Section 4(f) property(s) would occur.

 Coordinate with officials with jurisdiction over other potentially affected 4(f) properties to confirm 

property boundaries and to identify planned facilities.

 Determine, through more detailed design and coordination with officials with jurisdiction, if a 4(f) 

property can be avoided or use minimized, including analysis of alignment refinements, retaining 

walls, steeper slopes or other design techniques. This activity also includes an analysis to 

identify the type of use of each protected property (temporary, permanent, constructive), if any, 

that would occur, as well as determine whether a permanent use can meet the criteria for a de 

minimis impact.

 Coordinate with the public to obtain their input on the potential uses.

 Conduct a least overall harm analysis if more than one alternative is developed as part of the 

Tier 2 NEPA document and no reasonable and prudent alternative to using a Section 4(f) 

property exists. The least harm analysis will determine which alternative would cause the least 

overall harm in light of the Section 4(f) statute’s preservation purposes. 

 Develop appropriate mitigation measures for any unavoidable uses of Section 4(f) properties.

Undertake and document all possible planning to minimize harm to each property where a 4(f) 

property cannot be avoided.

The Project Team does not anticipate that this Section 4(f) determination in Tier 2 will have an effect 

on decisions made during Tier 1. The Tier 1 corridor level analysis is specifically designed to focus 

decision-making on selecting the best corridor for the Project based on the key factors at the Tier 1 

stage: ridership, cost, and parklands and cultural resource effects, and other areas where readily 

available data are available for the broad level analysis that was conducted in this Tier 1 DEIS. If a 

Corridor Alternative is selected, the wide buffer areas used in Tier 1 give FRA, GDOT, and TDOT

the flexibility to determine and refine one or more alignments within the selected buffer area, and to 

avoid or minimize impacts and uses of resources including Section 4(f) properties during Tier 2. 
Chapter 5 Costs and Funding

Atlanta-Chattanooga HSGT Tier 1 DEIS 5-1 September 2016

5.0 COSTS AND FUNDING

5.1 Introduction

This chapter provides preliminary, order of magnitude capital cost estimates to build the Corridor 

Alternatives. It also provides initial estimates of projected operating revenue and discusses the 

funding sources by which the project sponsor may construct and operate the potential Corridor

Alternative ultimately selected, if one is selected. Detailed capital, operating and maintenance cost 

development, operating surpluses and deficits, and financial capacity analysis are deferred to future 

analysis. 

5.2 Estimated Capital Costs 

The following describes the estimated cost to design and construct each of the three Corridor

Alternatives proposed for the Atlanta-Chattanooga HSGT system. The preliminary capital cost 

estimates were categorized into the Federal Railroad Administrations (FRA’s) Standard Cost 

Categories (SCCs) for Capital Projects/Programs, described below, and estimated by determining 

the appropriate unit costs and the cost element quantities from conceptual alignment and station 

option plans prepared for each proposed Corridor Alternative. 

 SCC 10 – Track Structures and Track. This category consists of:

o Track items such as double/single track on at-grade, structure, tunnels, and retained section.

o Earthwork – site preparation, cut, fill, erosion control, fencing and special drainage. 

o Structures, tunnels, walls – viaducts and bridges (standard, high, and long span), water 

crossings, tunnels (tunnel boring machine, mined, soft ground, cut and cover), crossovers, 

trench, retaining walls, containment walls, mechanical and electrical for tunnels. 

o Grade separations – over and under crossings in urban and minor street closures.

 SCC 20 – Stations, Terminals, Intermodal. This category consists of terminal stations, line 

stations (two/four track), fare collection, vertical circulation, site development, parking, etc. 

 SCC 30 – Support Facilities: Yards, Shops, Administrative Buildings. This category consists of 

vehicle storage and maintenance facilities and associated tracks, maintenance and operations 

buildings, site development, and parking.

 SCC 40 – Sitework, Right-of-Way, Land, Existing Improvements. This category consists of rail 

and utility relocation/removal, real property acquisition and owner/business relocation, etc. 

Environmental mitigation – mitigation of environmental impacts such as impacts to wetlands, 

parkland, biological resources, wildlife habitat, communities, and hazardous material cleanup. 

Environmental mitigation is estimated as three percent of construction costs and based on the 

average total cost of mitigation.

 SCC 50 – Communications and Signaling. This category consists of system elements including 

signals, communication, wayside protection, traction power, and distribution.

 SCC 60 – Electric Traction. Included within SCC 50 for this Tier 1 DEIS.

 SCC 70 – Vehicles. Costs associated with the vehicles and equipment needed to operate the 

service are not included in this Tier 1 DEIS. They will be addressed in future NEPA document(s). 

 SCC 80 – Professional Services. This category consists of program implementation costs added 

as a percentage (25.5 percent) of construction and procurement costs. It includes preliminary 

engineering, environmental review, design management, final design, procurement, construction 

management, agency costs, risk management and testing, and pre-revenue operations.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 5-2 September 2016

 SCC 90 – Unallocated Contingency. This category consists of a cost added as a percentage (25 

percent) of overall costs to account for uncertainties at the program level of analysis. It is based 

on past experience for projects at an early stage of definition.

 SCC 100 – Financial Charges. Included within SCC 80 for this Tier 1 DEIS.

More detailed cost estimates will be developed during subsequent Tier 2 analysis.

The preliminary capital cost estimates for the Corridor Alternatives are presented in Table 5-1. Costs 

were estimated for year 2014 dollars and are in constant dollars. These costs reflect those elements 

associated with planning, design, and construction of the alternatives and reflect the physical 

features associated with potential alignments including stations, track and bridge improvements, and 

other infrastructure. The level of engineering is of a conceptual nature at this stage of project 

development and uses steel-wheeled track and system elements costs. Future analysis will 

differentiate between steel-wheeled and Maglev train technologies, which typically carry higher 

capital costs than steel-wheel. Maglev systems require tighter construction tolerance allowance, 

larger radius curves, and longer point of vertical curves versus steel wheel locomotives. Each of 

these brings a higher cost in materials, field labor, and design time. Maglev also requires 

electrification costs that are above those of steel wheel locomotives. Maintenance facility costs for 

diesel exhaust must be accounted for in the design and construction of the facility since it must 

either be captured and released outside of the building for interior air quality purposes or diluted by 

high volume exhausting. Likewise, Maglev requires a shop and yard electrification system. 

Table 5-1: Estimated Capital Costs

Cost Elements

Corridor Alternatives 

(Millions in 2014$)

I-75 East I-75/ Rome

SCC 10 - Track Structures and Track

Track 378 370 396

Earthwork 241 1,978 911

Structures, Tunnels, Walls 3,059 2,574 2,843

Grade Separations 341 124 333

SCC 20 - Stations, Terminals, Intermodal 607 586 627

SCC 30 – Support Facilities: Yards, Shops, Administrative

Buildings 154 154 154

SCC 40 – Sitework, Right-of-Way, Land, Existing Improvements

Rail and Utility Relocation 53 32 48

Right-of-Way 282 306 394

Right-of-Way for Stations and Site Development 25 30 30

SCC 50 – Communications and Signaling and SCC 60 – Electric 

Traction 339 366 403

Subtotal of Construction Cost 5,480 6,518 6,137

SCC 90 – Unallocated Contingency (25% of Construction) 1,370 1,629 1,534

Subtotal of Construction Cost w/Contingencies 6,849 8,147 7,671

SCC 80 – Professional Services and SCC 100 – Financial 

Charges (25.5% of construction and procurement) 1,747 2,078 1,956

Total Construction Cost, Contingencies, Vehicles and Program 

Implementation 8,596 10,225 9,627

Environmental Mitigation - 3% of construction cost (SCC 40) 164 196 184

Total Project Cost $8,760 $10,420 $9,811 

Source: Atlanta to Chattanooga HSGT Project Team 2014

Note: Figures may be subject to rounding discrepancies.
Chapter 5 Costs and Funding

Atlanta-Chattanooga HSGT Tier 1 DEIS 5-3 September 2016

5.3 Operating and Maintenance Costs

GDOT and TDOT have deferred the development of detailed operating and maintenance (O&M) 

cost estimates to future Tier 2 NEPA analysis when the preferred mode will be selected. The O&M 

cost estimates of the Preferred Alternative will be based on daily train miles, operating speed, travel 

time, energy consumption, station configuration, maintenance and storage facilities, assumed 

operating frequencies, labor time requirements and staff salaries, and routine maintenance 

schedules. 

5.4 Estimated Operating Revenues

Table 5-2 presents the estimated daily and annual operating revenues for each of the Corridor

Alternatives. The basis for operating revenues is ridership forecasts, which are generated from the 

ridership forecasting model. Ridership forecasts are based upon proposed routes and proposed 

station stop locations, operating speeds and travel times, service frequencies, and fares. Ridership 

forecasts were not sensitive to a specific type of train technology or associated passenger capacity 

limitations; therefore, ridership and revenues are equivalent between Maglev and steel-wheeled 

technology options.

Table 5-2: Estimated Annual Operating Revenue for the Year 2040

Year 2040 Revenues

Corridor Alternative

I-75 East I-75/Rome

Daily $420,300 $260,300 $519,300

Annual* $136,597,500 $84,597,500 $168,772,500

Source: Atlanta to Chattanooga HSGT Project Team 2014

*Assumed 325 revenue days per year to account for lower ridership during weekends and holidays.

For the purposes of estimating operating revenues for this Tier 1 DEIS, an assumed fare structure 

was used that allows for consistent comparison across alternatives. A distance-based fare of $0.75 

per mile (2014$) and a $14.00 (2014$) boarding fee were assumed for inter-city service. For intraAtlanta trips, a flat $14.00 fare was assumed, with an additional $7.00 for trips to/from HJAIA airport 

(all monetary values in 2014$). These fares were developed for testing purposes and not intended to 

be either revenue-maximizing or ridership-maximizing. They were calculated using similar values to 

other high-speed intercity rail projects around the country. Further refinement of fare structures will 

occur during subsequent study and policymaking processes. 

5.5 Potential Funding Sources

The implementation of a state supported project to provide the proposed HSGT service will require a 

well thought out funding strategy. This section describes federal, state, local, and other funding 

options that could help fund the selected alternative (see Table 5-3). The funding strategy will need 

to address two key areas: 1) capital funding for infrastructure and train equipment and 2) operating 

support if required, to supplement ticket revenues.

The basic funding model for the proposed HSGT service in the U.S. is to use public sector grant 

funds to capitalize the proposed project’s infrastructure needs to implement a new service or achieve 

a desired level of service. Public sector capital funding is generally required for the following: 

 Project development activities including: planning, environmental compliance (NEPA), 

preliminary engineering (PE), and final design (FD); 

 Infrastructure construction: track, signals, and stations; and

 Acquisition of operating equipment and construction of maintenance facilities.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 5-4 September 2016

Table 5-3: Federal, State, and Local Funding and Financing Sources

Federal Capital Grant Programs

FRA High Speed and Intercity Passenger Rail Program 

(Sections 301, 302, 501 of the Passenger Rail Investment and Improvement Act of 2008 (PRIIA))

Transportation Investment Generating Economic Recovery (TIGER) Discretionary Grant Program

Federal Financing and Loan Programs

USDOT Transportation Infrastructure Finance and Innovation Act (TIFIA)

Railroad Rehabilitation and Improvement Financing (RRIF)

FHWA Section 130 Highway Railroad Grade Crossing Safety Program

FRA High Speed Rail Crossing Improvement Program

FHWA Surface Transportation Program

FHWA CMAQ Funds

FHWA Grant Anticipation Revenue Vehicle Bonds

IRS Tax Exempt Private Activity Bonds 

State and Local Capital Match Funding

State General Fund Appropriations

State General Obligation and Revenue Bonds

Freight Railroad Contributions

Local General Fund Appropriations

Local Bonding

Joint Development

Public Private Partnerships

Specialized State Grant Programs

Value Capture Taxes - Land Value Taxes, Local Tax Incremental Financing and Tax Allocation Districts 

Community Improvement Districts, Developer Impact Fees, Air Rights

Specialized Local Funding Programs - Georgia Special Purpose Local Option Sales Tax, Georgia House Bill 

277, Tennessee Gasoline Tax for Local Transportation Funding

Operating Support Funding

State Appropriations

FHWA CMAQ Funds 

Revenue Maximization Strategies

Operating Cost Control Strategies

Federal Capital Funding

Capital funding will typically come from federal grant sources, shown in Table 5-3, and will be 

matched with state funds. Local participation is usually limited to such things as station development 

and corridor acquisition in urban areas for joint transit use. Where infrastructure improvements 

benefit freight operations, private railroads may also be a source of matching funds. 
Chapter 5 Costs and Funding

Atlanta-Chattanooga HSGT Tier 1 DEIS 5-5 September 2016

The goal of the capital investment program is to provide an enhanced level of service with the 

potential to increase revenues and to reduce and/or eliminate operating subsidies. Where on-going 

operating support is required, funding will have to be provided by state sources, generally through 

annual appropriations, although there may be opportunities for limited federal funding sources such 

as the Congestion Mitigation and Air Quality (CMAQ) Improvement Program or Traffic Mitigation 

Programs.

State and Local Funding

The majority of existing state-funded corridor services require some kind of on-going state operating 

support. Given the limited federal funding available to states, an important strategy for reducing 

operating support requirements is to create a service development plan that maximizes ridership and 

revenues through competitive travel times, accessible stations, aggressive pricing, targeted 

advertising, traveler amenities, and low-cost feeder bus operations. State and local agencies would 

need to identify sources of funding to support any operating subsidies. 

Operating Funding

The service development planning process should also seek to minimize operating costs through 

negotiations with Amtrak or other passenger service operators, and vendor maintenance of 

equipment. 

Other Considerations

The experience in Europe, Asia, and in Amtrak’s Northeast Corridor (Acela Express) between 

Washington D.C., New York, and Boston is that passenger high-speed ground transportation service 

between major population centers can generate an operating profit. This profit can be used to retire 

a portion of the capital cost for equipment and infrastructure or provide funds for future capital 

maintenance activities.

Various governmental and private financing tools can be used as a secondary source of capital to 

maximize the leverage offered by a funding stream derived from net operating revenues. Federal 

financing tools include low interest direct loans, loan guarantees, and federal interest tax 

exemptions. 

Loans supported by governmental financing tools and strategies can be useful for capital

investments where HSGT passenger service is being provided by a special purpose governmental 

authority with taxing powers or access to dedicated tax revenues such as a local sales tax. 

Specialized financing tools such as tax incremental financing are also useful for public private 

partnerships at the local level to develop joint use passenger stations with various retail, food 

service, car rental, hotel, and housing opportunities. 

Potential federal, state, and local funding and financing sources are listed in Table 5-3 in terms of 

their application as: 1) sources of federal capital funding and financing, 2) state and local sources of 

capital match funding, and 3) sources of operating funding. 

5.5.1 Funding Sources and Strategies for Operating Support

State Appropriations

Nationally, the predominant source of public sector operating support in cases where revenues do 

not cover operating costs is the use of annual state appropriations. Most states currently contract 

with Amtrak to provide service given that Amtrak has a federal right of access to provide passenger 

rail service on existing freight lines at an incremental cost. Amtrak then charges each state for any 
Chapter 5 Costs and Funding

Atlanta-Chattanooga HSGT Tier 1 DEIS 5-6 September 2016

operating costs not covered by operating revenues. Other entities seeking to operate on freight rail 

would have to negotiate access under a separate agreement, which may not carry the same cost 

benefits.

The challenge in using the annual state appropriations process to fund HSGT passenger service is 

that estimates must be made each year in advance of actual expenditure. If there is an unforeseen 

increase in factor costs such as fuel or labor, it may be difficult to adjust the appropriations level 

because of the long lead-time required by the state budget and appropriations process. The use of 

multi-year operating contracts is one mechanism to manage the uncertainty associated with the 

state budgetary process and potential changes in factor costs. 

FHWA Congestion Mitigation and Air Quality Funds

Start-up operating expenses for intercity passenger HSGT service are eligible for FHWA CMAQ 

funding for the first five years of operation. These provisions are clarified in the July 2014 Revised 

Interim Guidance on CMAQ Operating Assistance under MAP-21. The proposed project must be in a 

federally designated non-attainment area and demonstrated to contribute to the attainment or 

maintenance of the air quality standard through reduction in vehicle miles traveled, fuel consumption 

or through other factors. The regulations include eligibility for corridors where a portion of the 

corridor is in a nonattainment area. The federal cost share is typically 80 percent. 

Revenue Maximization Strategies

While not a direct funding source, a revenue maximization strategy should be a key part of any state 

approach to minimizing state operating subsidies for intercity passenger HSGT service. This strategy 

begins in the service development planning process and continues through start-up and on-going 

operation. Elements for consideration in a revenue maximization strategy include service levels, 

intermodal connectivity, feeder bus networks, aggressive ticket pricing, traveler amenities, and 

advertising and marketing campaigns. 

Setting an appropriate level of service to maximize revenues involves increasing frequencies, 

speeds, and other service features to the point that marginal ridership and resulting revenues equal 

marginal operating costs. Generally, this means adding infrastructure and equipment improvements 

to increase frequencies and decrease travel times until they are substantially less than auto travel 

times in the same corridor. An integrated feeder bus network scheduled to meet arriving and 

departing trains is another low cost, low risk method to increase ridership. Other approaches to 

encourage intermodal connectivity for local transit, bike/pedestrian, intercity bus, and air are also 

important. 

States generally have flexibility in their ticket pricing strategy and often under-price state-supported 

passenger rail services. Airline-type “revenue yield maximization” strategies including time-of-day, 

day-of-week, and seasonal pricing can also be considered. State sponsored passenger HSGT 

service is ultimately a business, and revenue maximization pricing is preferred over ridership 

maximization to insure its long-term financial viability. 

Provision of on-board amenities, such as wide seats and ample leg room, food service, and onboard video and audio programming also attracts travelers. Wi-Fi access and 110-volt plug-in 

access for laptops, cell phones, and other productivity enhancement devices used by travelers are 

other potential amenities. HSGT travel is a new experience for many and an aggressive advertising 

and on-going marketing program is an important and cost-effective means to maximize ridership. 

Operating Cost Control Strategies

An operating cost control strategy, while not a funding source, should be a key part of a state’s 

approach to minimizing state operating subsidies. An operating cost control strategy should begin in 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 5-7 September 2016

the service development planning process and continue through start-up and on-going operation. 

Elements for consideration in an operating cost control strategy include competitive bidding for the 

state operating franchise, careful negotiations with Amtrak or other operators, maintenance of 

operating equipment by the manufacturer or other outside vendor, outsourcing of food service, 

cleaning services, station operations, and other activities. 

The use of competitive bidding offers an opportunity to reduce or possibly eliminate the need for 

state operating support funding. Under this approach, the state award of a passenger HSGT service 

franchise would go to the proposal that has the greatest operating surplus or least public operating 

subsidy requirement. For projects with the potential to generate an operating surplus, bidders could 

also be asked to quantify the proportion of the required capital investment they would be willing to 

finance. This approach may work best for new HSGT services operating in dedicated “greenfield” 

corridors between major population centers. 

Negotiations with Amtrak or other operators in developing an operating contract can also be used to 

control specific cost items. For example, some states have taken on the responsibility for 

reservations and information call centers to reduce contract costs. Other states have eliminated 

reserved service to eliminate it as a cost item. 

Limited food service can be offered by vending machines, and the use of carts for point of sale food 

service can be cheaper than operating a dining or bistro car. During periods of upward (or 

downward) uncertainty in fuel costs, Amtrak or other providers may agree to put these costs outside 

of an operating agreement. States may find this advantageous to accepting a high-end contract cost 

if they have the flexibility to budget for a range of fuel costs outside of a fixed cost contract. 

Finally, states can consider contracting out a variety of services, which might be provided by the 

state more cheaply than through the operator including delivery of operating equipment maintenance 

services by the equipment manufacturer, as well as contracting out food service, cleaning services, 

and other activities. 

5.5.2 Federal and State Capital Funding Assumptions and Requirements

As discussed in Section 5.2, the preliminary capital cost estimates for the proposed project range 

from $8.7 to $10.4 billion depending on the alternative selected. Similar to the development of the 

interstate highway system, this level of capital investment would require a significant federal funding 

component. The FRA’s High Speed and Intercity Passenger Rail (HSIPR) Program, as authorized 

under the 2008 Passenger Rail Investment and Improvement Act (PRIIA), could offer the best model 

for current and expected future federal funding for intercity passenger HSGT development. The 

basic feature of this program is the provision of 80 percent federal grants to states for intercity 

passenger HSGT planning, design, and construction. However, due to the uncertainties with federal 

funding sources, other financing sources will need to be further investigated during future studies.

Given the magnitude of the federal grant match requirement, state bond funds are the most likely 

source of funding for this kind of state capital investment, subject to state statutory and constitutional 

limitations. Assuming state bond funds will be used to fund the required state match, the annual cost 

to Georgia and Tennessee would need to be determined during future study.

Given this, potential public private partnerships (P3s) could be investigated whereby the state would 

put the operating franchise out for bid as a design-build-operate-maintain project and then select the 

operator willing to finance the greatest portion of the proposed project from the operating surplus. 

The state would have to maintain ownership to finance any portion of the proposed project with 

General Obligation (GO) bonds. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 5-8 September 2016

5.6 Risk and Uncertainty

A large-scale project such as the Atlanta – Chattanooga HSGT Project faces many risks due to 

multiple participants and unknowns such as funding sources, and actual revenue and ridership 

numbers. Assessing potential risks and investigating mitigating factors before the start of project 

construction will be necessary. As with any transportation project, there are general risks such as 

capital funding, revenue, operating cost, environmental, institutional, and schedule risks. However, in 

the case of the Project, there are also unique risks such as intergovernmental risks associated with 

the need for two independent state governments to agree on the many aspects of the service and its 

costs. This section outlines these general and unique risks, and suggests possible mitigation 

measures. Table 5-4: Potential HSGT Project Challenges summarizes an initial discussion of 

project risks. 

5.6.1 Risk Assessment 

The highest risks identified in Table 5-4 are federal capital funding risks, intergovernmental risks, 

and operating cost and financial feasibility estimation risks. Of these, the greatest risk is the federal 

funding risk, given the magnitude of the capital funding needs associated with the Project. The future 

federal funding Congress authorized as part of Fixing America’s Surface Transportation Act (FAST 

Act), passed on December 4, 2015, provides funding for the following three new competitive rail 

development grant programs:

1. Consolidated Rail Infrastructure & Safety Improvements Program - To improve the safety, 

efficiency, and reliability of passenger and freight rail systems

2. Federal-State Partnership for State of Good Repair Program - To reduce the state of good 

repair backlog on publically-owned or Amtrak-owned infrastructure, equipment, and facilities

3. Restoration & Enhancements Program - For operating assistance to initiate, restore, or 

enhance intercity passenger rail transportation

However, these programs are competitive. Without a guaranteed, multi-year source of federal 

funding for intercity passenger service, large-scale transportation projects such as the proposed 

HSGT service in the Project Area could be difficult to implement.

Intergovernmental risk is the next highest risk. Intergovernmental cooperation and coordination 

between Georgia and Tennessee will be critical for this proposed project to move forward. If federal 

funding is available on an 80 percent basis, as in the current HSIPR and federal highway programs, 

a 20 percent state share requirement has the potential to be seen by state elected officials as an 

opportunity to leverage a significant amount of federal funding to benefit the citizens of their state. 

However, the match requirement is significant because there are many competing priorities for state 

dollars, which will likely vary in each state. 

Coordination has to been seen in the context of the federal system under the U.S. Constitution 

where states are legally described as “sovereigns” - able to set their own independent political 

courses, subject to only specific powers delegated to the federal government. Only goodwill and 

well-defined mutual self-interest will bring about a coordinated and agreed upon service plan, 

funding plan, and a schedule for a project of this magnitude.

Further, operating cost and financial feasibility estimation risks are related to intergovernmental 

coordination. Unlike capital cost estimation risks, which can be controlled through the preliminary 

engineering and the final design cost estimation and bidding process; operating costs and the 

absolute financial feasibility of the proposed project will only be known once the service is initiated. 

The P3 process, where the project franchise is competitively bid and awarded to a private sector 

operator, is a strategy for minimizing this risk to the public sector.
Chapter 5 Costs and Funding

Atlanta-Chattanooga HSGT Tier 1 DEIS 5-9 September 2016

Table 5-4: Potential HSGT Project Challenges

Challenge Type Description Potential Solution

Funding Challenges

Federal Capital  New Surface Transportation Program: FAST Act

 No aannual appropriations under PRIIA

 Utilize surface transportation block grant program to leverage 

potential for public-private partnerships

State Capital  State bonding capacity 

 Impact on credit rating

 Investigate federal TIFIA or Railroad Rehabilitation & Improvement 

Financing (RRIF) loans or loan guarantees to minimize impact on 

state credit ratings. 

State Operating 

Support Funding  The need for annual general fund appropriations  Prepare service development plan focusing on maximizing revenues 

and minimizing operating costs.

Environmental Challenges

NEPA  Potential cost impacts of environmental resources yet to be 

identified 

 Conduct NEPA studies early in the design process.

 Start mitigation efforts early for any environmentally sensitive areas.

Estimations/Forecast Challenges

Capital Cost  Additional costs identified after detailed preliminary engineering 

and design

 Move promptly to 30 percent PE and project NEPA stage to refine 

costs. 

Financial 

Feasibility

 “Planning level” financial analysis nor “investment grade” at this 

stage

 Prepare financial analysis based on refined cost estimates and a 

detailed operating plan. 

Operating Cost  Variations in operating costs after execution of contract with 

operator

 Conduct an in-depth cost analysis to more accurately estimate 

operating costs.

 Develop long term operating cost forecasts that address cost 

changes associated with increases in ridership and/or service levels 

over time. 

Ridership and 

Revenue  Market conditions impact on actual ridership and revenue

 Promote ridership via strategic station location.

 Conduct marketing activities – incentives program

Schedule Risk

 Additional costs due to governmental decision-making and funding 

delays as it relates to authorization of a new “Surface 

Transportation Program”

 Changes in Project Scope

 Changes in Design or Operating Standards

 Unforeseen Issues in Implementation

 Develop proactive relationships with federal agency staff at all levels 

to insure project receives proper priority for agency action.

Technology

 Limited information available for HSGT train technologies 

 Other train technologies may be available when construction 

begins

 Continue to monitor technology throughout PE and design.

 To the extent possible, ensure flexibility in system design.

Institutional Challenges

Intergovernmental

 Legislative and executive action needed concurrently by two 

“sovereign” states

 States may not have similar priorities in capital contributions, 

timing, etc.

 Develop multi-state compacts – with agreement upon schedule and 

cost sharing.

 Develop memorandum of agreement with local municipalities.
Chapter 5 Costs and Funding

Atlanta-Chattanooga HSGT Tier 1 DEIS 5-10 September 2016

5.7 Summary of Funding Analysis

Chapter 5 summarizes the capital costs and revenues for the three Corridor Alternatives 

considered. In addition, an analysis of funding and financing options available to the states of 

Georgia and Tennessee as they consider the implementation of the proposed HSGT service in the 

Project Area were considered. Based on this, several conclusions can be reached:

 Significant federal funding will be required to implement the proposed HSGT service in the 

Atlanta – Chattanooga Project Area. At least a 20 percent state match share will likely be 

required. 

 The most likely source of funding for the state match share will be state GO bonds. 

Supplementary federal financing may be required using federal loans or loan guarantees offered 

by federal programs like the Transportation Infrastructure Finance and Innovation Act (TIFIA) or 

Railroad Rehabilitation and Improvement Financing (RRIF).

 A competitively bid design-build-operate-maintain franchise structure has the potential to offer 

the least cost and lowest risk to the states. This could potentially develop into a P3.

These conclusions should be analyzed, refined and confirmed in a more detailed “investment grade” 

financial analysis if a Preferred Alternative is selected.

5.8 Subsequent Analysis

Following the selection of a Preferred Alternative, a financial capacity analysis will be necessary. 

This will rely upon capital costs developed for a more precisely engineered alignment, and refined

operating plans and fare structures. These will allow for development of operating and maintenance 

costs estimates, calculation of operating surpluses and deficits, and formulation of state bonding 

assumptions and requirements. 

The goal of financial planning will be to develop an understanding of the financial aspects of the 

proposed action through an examination of funding sources and the allocation of those funds. 

Preparing a cash flow projection of the proposed action clarifies this understanding. The cash flow 

projection compares the income and expense potential of the following elements:

 Capital cost estimates;

 O&M cost estimates;

 Fare revenue estimates; and

 Other sources of funds.

The financial analysis will discuss and explore funding options that address capital and operating 

fund shortfalls discovered during an evaluation of the cash flow projections. Again, more detailed 

financial analysis and cash flow projections will be required in subsequent stages of project 

development. 
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-1 September 2016

6.0 EVALUATION OF ALTERNATIVES

6.1 Introduction

Chapter 6 provides a summary evaluation of the No-Build and Corridor Alternatives. The evaluation 

contained in this chapter is an assessment of the findings presented in preceding chapters of this 

Tier 1 DEIS, along with a comparative discussion of the benefits and effects of the alternatives 

considered. The evaluation provides the basis for decision-makers and the public to consider the 

trade-offs in selecting an alternative corridor to advance to further study.

In this chapter, the No-Build and Corridor Alternatives were evaluated based on their ability to meet 

the Project purpose and need, and on consideration of their relative benefits and consequences. 

Table 6-1 summarizes the data findings for the Corridor Alternatives; these data are discussed in the 

subsections below.

Table 6-1: Comparative Summary of the Corridor Alternatives

Needs Measures Corridor Alternative

I-75 East I-75/Rome 

Enhance regional 

transportation mobility 

and accessibility

Time to Travel Alternative End to End 

(minutes) 88 95 102

Population within 10 miles of 

Proposed Station Locations (millions) 2.85 2.86 2.95

Employment within 5 Miles of 

Proposed Station Locations 

(thousands)

869 870 894

Daily Ridership (number of boardings) 11,725 8,556 13,204

Spur economic growth 

and regional vitality

Capital Cost (steel wheel only; 2014$ 

millions) $8,760 $10,420 $9,811

Provide safe, efficient, 

reliable transportation

Provide passenger HSGT service on 

exclusive guideway Yes Yes Yes

Enhance airport access 

and intermodal 

connections

Provide access to HJAIA and CMA; 

connect to MARTA, GRTA and CCT 

service areas

Yes Yes Yes

Improve air quality 

nonattainment areas and 

minimize environmental

impacts

Proportion of Corridor Alternative 

within an Existing Transportation 

Corridor (percent)

76 31 53

Ratio of EJ areas to overall corridor 

(based on linear miles) 0.6:1 0.5:1 0.5:1

Ratio of Station Areas with and 

without EJ populations 6:2 6:2 6:2

Noise-sensitive Land Uses (acres) 5,914 7,519 8,425

Vibration-sensitive Land Uses (acres) 891 1,695 1,372

Parklands and Wildlife Refuges 

(acres) 443 447 442

Parklands and Wildlife Refuges 

(number) 25 19 30

Known Archaeological Resources 

(number) 32 46 38

Known Historic Resources (number) 26 66 33

Cemeteries (number) 4 3 5

Wetlands (acres) 205 205 251

Stream Crossings (number) 21 18 35

Floodplains (acres) 1,563 2,576 1,689

Known Threatened and Endangered 

Species Habitats (number) 21 38 21

Known Threatened and Endangered 

Species Habitats (acres) 1,907 2,158 1,817
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-2 September 2016

6.2 Effectiveness in Meeting the Purpose and Need 

As presented in Chapter 1, the Project is intended to enhance intercity mobility and economic 

growth throughout the Project Area between the metropolitan areas and the airports of Atlanta, 

Georgia, and Chattanooga, Tennessee, by providing faster and more reliable ground transportation 

service to the traveling public as an alternative to highway, intercity bus, and air travel in a manner 

that is safe and cost-effective, while avoiding, minimizing, and mitigating impacts on the human and 

natural environment.

6.2.1 Enhance Intercity Mobility

The first purpose of the Project is to enhance intercity mobility throughout the Project Area between 

the metropolitan areas and the airports of Atlanta, Georgia and Chattanooga, Tennessee. 

No-Build Alternative

The No-Build Alternative projects would address congestion, access and safety issues in selected 

portions of the Project Area transportation network, but would not enhance intercity mobility 

throughout the Project Area between the metropolitan areas and the airports of Atlanta, Georgia and 

Chattanooga, Tennessee. The No-Build Alternative will not achieve this Project purpose. 

Corridor Alternatives

Each Corridor Alternative would achieve this purpose by providing new HSGT in the Project Area

that:

 Provides intercity travel capacity to supplement over-used interstate highways;

 Meets future intercity travel demand that cannot be accommodated by existing and No-Build 

Alternative transportation systems; 

 Provides intermodal connections with local transit, major airports and highways; 

 Increases transportation access in terms of population and employment; and

 Supports population and employment growth through improved access.

However, the Corridor Alternatives differ in ridership performance, as noted in Table 6-1:

 The I-75/Rome Corridor Alternative would have the highest ridership, followed by the I-75 

Corridor Alternative; the East Corridor Alternative would have the lowest ridership. 

6.2.2 Enhance Economic Growth

The second purpose of the Project is to enhance economic growth throughout the Project Area

between the metropolitan areas and the airports of Atlanta, Georgia and Chattanooga, Tennessee. 

No-Build Alternative

The capital cost of the No-Build Alternative would include the costs to construct the No-Build 

Alternative projects described in Chapter 2. The No-Build Alternative would be implemented 

whether a Corridor Alternative is constructed or not, but the No-Build Alternative would produce less 

growth in the tax base and employment compared to a Corridor Alternative. The No-Build Alternative 

has potential to increase accessibility to employment opportunities in some parts of the corridor, and 

may support some development of urban densities and associated economic activity in some parts 

of the corridor. However, the No-Build Alternative would achieve these benefits to a lesser degree 

than the Project; these benefits would be localized compared with the corridor-wide benefits of the 

Project. Thus, the No-Build Alternative would not achieve this Project purpose.
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-3 September 2016

Corridor Alternatives

Each Corridor Alternative would achieve this purpose by generating capital expenditures during 

construction and by providing an opportunity for growth in the tax base and employment at potential 

station locations during operation. Capital cost is the one measure for this purpose that differs 

among the Corridor Alternatives, as shown in Table 6-1. Specifically, the I-75 Corridor Alternative 

would have the lowest capital cost among the Corridor Alternatives, while the East Corridor 

Alternative would have the highest capital cost.16

6.2.3 Faster and More Reliable Ground Transportation Service

The third purpose of the Project is to provide faster and more reliable ground transportation service 

to the traveling public as an alternative to highway, intercity bus and air travel. 

No-Build Alternative

The No-Build Alternative projects would address localized congestion, access and safety issues to 

some degree, but would not individually or collectively provide corridor-wide benefits in terms of 

faster and more reliable ground transportation service to the traveling public as an alternative to 

highway, intercity bus, and air travel. The No-Build Alternative will not achieve this Project purpose. 

Build Alternatives

Each Corridor Alternative would achieve this purpose by providing a new HSGT service. The service 

would operate on dedicated rail or guideway unlike existing transportation services. For this reason, 

service reliability would be inherent under typical operating conditions. 

End to end travel times vary among the Corridor Alternatives as indicated in Table 6-1 with the I-75 

Corridor Alternative being the shortest at 88 minutes, the East Corridor Alternative at 95 minutes, 

and the I-75/Rome Corridor Alternative at 102 minutes. To put these durations into context, 

approximate existing transportation travel times from end to end are:

 Air – 120 minutes (includes 60 minutes arrival prior to departure and airport gate to gate)

 Intercity bus – 125 to 185 minutes

 Automobile (on I-75) – 110 minutes (non-peak)

All Corridor Alternatives would provide faster end to end service compared to intercity bus service or 

driving on existing roadways. The I-75 Corridor Alternative is closest in travel time to air if only flight 

time is considered and not time spent at the airports checking in, clearing security, and claiming 

baggage. End to end travel times with the I-75 Alternative are the shortest at 88 minutes, the East 

Corridor Alternative at 95 minutes, and the I-75/Rome Corridor Alternative at 102 minutes.

6.2.4 Safe and Cost-Effective Transportation Service

The fourth Project purpose contains two components: provide safe and cost-effective transportation 

service. FRA, GDOT, and TDOT place the safety of transportation users and the community at the 

forefront of this study as it considers the relative benefits and effects of each Corridor Alternative. 

 

16 The unit of measurement for capital costs is order-of-magnitude dollars and reflects the investment necessary to construct an 

HSGT system. Differentiation between the capital costs of Steel-Wheeled and Maglev technologies is not made since technology 

selection is not made within this Tier 1 DEIS. Steel-Wheeled technology capital costs were used in this case to ensure an equitable 

comparison of alternatives. The capital costs included in this estimate include track, structures, stations, utilities, ROW, design, and 

contingencies, as described in Chapter 5.
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-4 September 2016

No-Build Alternative

Safety is a key goal of any transportation project. For this reason, the sponsors of each No-Build 

Alternative project would consider safety as a priority in the design, construction and operation of 

their projects. However, because most projects in the No-Build Alternative are roadway projects, and 

because travel on roadways is relatively less safe than passenger rail/guideway travel according to 

FRA statistics, the No-Build Alternative is likely to perform less well compared to the Corridor 

Alternatives in achieving the safety component of the Project purpose and need. 

Corridor Alternatives

As the Tier 1 analysis focuses on corridor evaluations, and specific alignments will not be identified 

in this Tier 1 DEIS, specific safety elements of design and practice have not yet been developed. 

However, the conservative buffer areas of each Corridor Alternative provide opportunities to optimize 

safety in the future design of alignments. At this level of study, there are no distinguishing 

differences between the Corridor Alternatives in this regard. As FRA statistics indicate that 

rail/guideway travel is safer17 than automobile travel, and inasmuch as most of the No-Build 

Alternative projects are roadway improvements, the Corridor Alternatives would be more responsive 

to the Project purpose and need regarding safe travel than the No-Build Alternative.

Cost-effectiveness is a decision-making tool that compares the relative cost of a project with its 

performance to determine the relative economic benefit of an action. In this Tier 1 cost-effectiveness 

assessment, the capital cost of each Corridor Alternative is considered in light of the forecast 

ridership and travel time. Table 6-1 summarizes the data findings for each Corridor Alternative. 

Table 6-2 shows the trade-offs among the Corridor Alternatives, considering these cost-effective 

factors.

Table 6-2: Cost-effectiveness Comparison

Corridor Alternative Travel Time Ridership Capital Cost

I-75 Shortest Higher Least

East Longer Lowest Highest

I-75/Rome Longest Highest Higher

Table 6-2 indicates the following regarding the Corridor Alternatives:

 I-75 Corridor Alternative: The I-75 Corridor Alternative would have the shortest travel time, the 

second highest ridership, and the least cost. 

 East Corridor Alternative: The East Corridor Alternative would have a longer travel time than 

the I-75 Corridor Alternative, but shorter than the I-75/Rome Corridor Alternative; it would have 

the lowest ridership and the highest cost.

 I-75/Rome Corridor Alternative: The I-75/Rome Corridor Alternative would have the longest 

travel time, but it would have the highest ridership; it would cost more than the I-75 Corridor 

Alternative but less than the East Corridor Alternative.

 

17 In 2011, the number of U.S. fatalities on passenger trains was six passengers or under 1 percent of all transportation fatalities in 

comparison to autos, which were 32,367, or approximately 94 percent (FRA 2011).
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-5 September 2016

6.2.5 Avoid or Minimize and Mitigate Impacts on the Human and Natural 

Environment

The fifth purpose of the Project is to avoid or minimize and mitigate impacts on the human and 

natural environment. 

No-Build Alternative

The projects in the No-Build Alternative would incur costs and potential effects on the human and 

natural environment that would be determined by the sponsors of those projects. As the geographic 

scope and nature of the No-Build Alternative projects is limited, the potential effects of the projects 

are likely to be limited. However, the No-Build Alternative would not improve air quality because it 

would not reduce the quantity or the growth rate of mobile source emissions resulting from vehicle 

miles traveled on the highway network in the Project Area. Thus, the No-Build Alternative would not 

achieve this Project purpose.

Corridor Alternatives

As the Tier 1 analysis focuses on corridor evaluations and specific alignments will not be identified in 

this Tier 1 DEIS, specific elements of design are not yet developed. However, the conservative 

buffer areas of each Corridor Alternative provide opportunities to avoid or minimize impacts on the 

human and natural environments in the future design of alignments. Nevertheless, at this level of 

study, several differences among the Corridor Alternatives were identified:

Use of Existing Transportation Corridors. To avoid or minimize impacts on the human and natural 

environments, GDOT and TDOT determined that the Corridor Alternatives should use existing 

transportation corridors wherever reasonably feasible. By using existing corridors, such as existing 

highway rights-of-way, there is a reduced likelihood of effects that result of property acquisition and 

disturbance of previously undisturbed areas. Table 6-1 indicates the percent of each Corridor 

Alternative within an existing transportation corridor. The I-75 Corridor Alternative would use the 

most existing right-of-way, followed by the I-75/Rome Corridor Alternative. The East Corridor 

Alternative would use the least percentage of existing transportation corridors, thereby having the 

highest potential for effects according to this measure.

Population and Employment Access: With the exception of ridership and as shown in Table 6-1, the

mobility analysis findings in this Tier 1 DEIS indicate that the Corridor Alternatives perform similarly 

in terms of absolute numbers as measured by population access and employment access. Beyond 

the absolute numbers, however, these factors provide some clarity as to who specifically is counted 

in those numbers. County-based 2010 U.S. Census data demonstrate that the Corridor Alternatives 

have varying characteristics regarding race and income. As shown in Figure 3-7 in Chapter 3, more 

urbanized areas typically have higher densities of minority and low-income populations compared 

with rural areas. 

The ratio of environmental justice (EJ)18 areas to non-EJ areas within each Corridor Alternative

corridor when measured by linear mile along each corridor is 0.6:1 for the I-75 Corridor Alternative

and 0.5:1 for the East and I-75/Rome Corridor Alternatives. Table 6-3 lists the proposed station 

areas served by each alternative and then summarizes:

 County-based demographics in terms of minority populations; and

 Station areas that are in high density areas of population and employment as indicated in 

Figures 3-5 and 3-6 in Chapter 3. 

 

18 Environmental justice (Executive Order No. 12898) is concerned with minority and low-income populations as defined in Chapter 

3 of this EIS.
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-6 September 2016

Table 6-3: Race, Population and Employment in Proposed Station Areas

Proposed Station Area

Race Density Area? Corridor Alternative 

Minority 

%

Primary Race 

Categories Pop Emp I-75 East I-75/ Rome 

HJAIA/ SC (not EJ) 59 Black, White ● ● ● ●

Downtown Atlanta (EJ) 59 Black, White ● ● ● ● ●

Cumberland/Galleria (EJ) 44 White, Black, 

Hispanic ● ● ● ● ●

Town Center (not EJ) 44 White, Black, 

Hispanic ● ● ●

Cartersville (EJ) 20 White, Black, 

Hispanic ● ●

Rome (EJ) 26 White, Black, 

Hispanic ●

Dalton (EJ) 38 White, Hispanic ● ●

Dalton-Chatsworth (EJ) 38 White, Hispanic ● ●

CMA (EJ) 28 White, Black ● ● ●

Downtown Chattanooga (EJ) 28 White, Black ● ● ● ● ●

Notes: Pop: Population; Emp: Employment; Density Area: using Figures 3-7 and 3-8, a presence score was determined by the 

occurrence of densities greater than 2.01 per acre.

Based on the Tier 1 level of analysis and subject to further analysis in Tier 2, each Corridor

Alternative has two potential station areas with no EJ populations: HJAIA and Town Center. The 

U.S. Census data for all other proposed station areas identifies EJ populations. Thus, in general, 

each Corridor Alternative’s potential station areas are primarily in locations also occupied by EJ 

populations. 

However, not all Corridor Alternatives serve the same potential station areas or the same EJ 

populations. For example, only the I-75.Rome Corridor Alternative would serve the proposed Rome 

station area. Similarly, only the East Corridor Alternative would serve the proposed DaltonChatsworth station area. The proposed Dalton-Chatsworth station area is a substantially higher 

population density area compared to Rome, but neither proposed station area is a high-density

employment area. By contrast, the I-75 and I-75/Rome Corridor Alternatives would serve Dalton, 

while the I-75 and East Corridor Alternatives would serve Cartersville. Thus, depending on the 

Corridor Alternative considered, Dalton, Dalton-Chatsworth, Cartersville, and/or Rome may or may 

not be served. Therefore, depending on the Corridor Alternative, some EJ populations in the study 

area would be served and some would not. 

Parklands: The difference between the Corridor Alternatives in terms of acreage of potentially 

affected parkland and wildlife refuges is insignificant; however, there is distinguishable difference in 

the number of parks or refuges that could be affected. The I-75/Rome Corridor has the highest 

number of potential parklands and the East Corridor has the least. 

Known Historic Resources: The East Corridor Alternative has twice the number of known historic 

resources as the I-75 or I-75/Rome Corridor Alternatives. The higher number is due to the East 

Corridor Alternative using a lower percentage of existing transportation rights-of-way. This 

differentiating factor suggests the potential for a higher number of Project impacts on known historic 

resources if the East Corridor Alternative is advanced.

Wetlands, Streams, and Floodplains: For the same reason, the I-75/Rome Corridor Alternative has 

more acres of wetlands and stream crossings than the other Corridor Alternatives. This difference 

suggests the potential for a higher number of Project impacts on wetlands, and streams if the I75/Rome Corridor Alternative is advanced. The East Corridor Alternative has a considerably higher 

acreage of floodplains compared with the other corridors.
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-7 September 2016

Known Threatened and Endangered Species Habitats: The East Corridor Alternative has a larger 

number of known threatened and endangered species habitats within the buffer area than the I-75 

and I-75/Rome Corridor Alternatives. This differentiating factor suggests the potential for a higher 

number of Project impacts on known threatened and endangered species habitats if the East 

Corridor Alternative is advanced.

Noise and Vibration: All Corridor Alternatives would have potential noise and vibration impact. The I75 Corridor Alternative is the best performing for both noise and vibration sensitive land uses within 

their respective screening distances. This may be attributed to the fact that a longer length of the I75 Corridor Alternative is adjacent to the interstate highway system, whereas the other two 

alternatives deviate from the interstate and travel along U.S. highways (which tend to have more 

development located closer to the roadway than interstate highways).

Air Quality: The I-75/Rome Corridor Alternative has the highest potential to transfer trips from the 

highway system to the HSGT and, thereby, reduce vehicular emissions. This finding is based solely 

on ridership. The I-75 Corridor Alternative would perform slightly less well followed by the East 

Corridor Alternative having the lowest potential.

In summary, despite the differences among the Corridor Alternatives, each Corridor Alternative

demonstrates some level of achievement of this Project purpose of avoiding or minimizing and 

mitigating impacts on the human and natural environment based on the data available at this Tier 1 

level of study and shown in Table 6-1. The East Corridor Alternative has the highest potential for 

impacts on known historic resources and floodplains and has the most vibration-sensitive land uses, 

while the I-75/Rome Corridor Alternative has the highest potential to impact wetlands and stream 

crossings and the most noise-sensitive land uses. Compared to the other Corridor Alternatives, the I75 Corridor Alternative has the lowest potential for noise and vibration impacts and impacts on 

known historic resources, streams, and floodplains; impacts on wetlands are similar to the East 

Corridor Alternative. 

6.3 Balancing Benefits and Effects

The transportation, economic, and air quality benefits of the Atlanta – Chattanooga HSGT Project

come with some potential negative effects. GDOT and TDOT have strived to avoid or minimize 

effects during Tier 1 analysis by aligning the Corridor Alternatives primarily along existing 

transportation corridors. The buffer areas provide opportunities to avoid or minimize impacts in future 

design. Yet some potential effects may not be avoidable given the developed character of some 

communities the Project is intended to serve, the design requirements of the Project, and the need 

to avoid affecting future operations of the existing transportation facilities in the corridors. 

Consequently, the decision to advance one alternative to the next phase of study involves 

recognizing and understanding that GDOT and TDOT are working to balance the trade-offs between 

the benefits and effects of the alternatives. 

Each Corridor Build Alternative would enhance intercity mobility and economic growth throughout 

the Project Area by providing safe, cost-effective, faster and more reliable high-speed ground 

transportation service between Atlanta, Georgia and Chattanooga, Tennessee. The high-speed 

ground transportation service provided by each Corridor Build Alternative would be competitive with 

existing highway, intercity bus, or air travel within the Project Area and each Corridor Build 

Alternative would avoid, minimize, and mitigate impacts on the human and natural environment.

Whereas the Corridor Alternatives perform similarly among many of the measures assessed, a 

number of measures reveal differences that distinguish the Corridor Alternatives: travel time, 

ridership, capital cost, amount of transportation corridor used, and potential impacts to known 

historic resources, wetlands, stream crossings, floodplains, known threatened and endangered 

species habitats, and parks and wildlife refuges. Table 6-4 focuses on these distinguishing 

measures.
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-8 September 2016

Table 6-4 compares how each Corridor Alternative performs with regard to the measures and 

identifies which of the three Corridor Alternatives are the best-performing, moderately-performing, 

and worst-performing with regard to each measure. The following describes the ratings assigned for 

each type of measure:

 A “Best-Performing Corridor Alternative” rating is associated with the fewest impacts 

(expressed in number and acreages), the shortest travel times, the lowest capital costs, and 

the highest daily ridership and proportion of the corridor alternative within an existing 

transportation corridor. 

 A “Worst-Performing Corridor Alternative” rating is associated with the most impacts, the 

longest travel times, the highest capital costs, and the lowest daily ridership and proportion 

of the corridor alternative within an existing transportation corridor.

 A “Moderately-Performing Corridor Alternative” rating is associated with quantities of 

impacts, travel times, capital costs, daily ridership, and proportion of the corridor alternative 

within an existing transportation corridor between those quantities exhibited by the “HighestPerforming Corridor Alternative” and “Lowest-Performing Corridor Alternative” for that 

particular measure. 

Table 6-4: Summary of Distinguishing Performance Measures

Needs Measures Corridor Alternative

I-75 East I-75/Rome 

Enhance regional 

transportation mobility 

and accessibility

Time to Travel Corridor Alternative End 

to End (minutes) 88 95 102

Daily Ridership (number of boardings) 11,725 8,556 13,204

Spur economic growth 

and regional vitality Capital Cost (2014$ millions) $8,760 $10,420 $9,811

Minimize environmental

impacts

Proportion of Corridor Alternative within 

Existing Transportation Corridor 76% 31% 53%

Noise-sensitive Land Uses (acres) 5,914 7,519 8,425

Vibration-sensitive Land Uses (acres) 891 1,695 1,372

Known Historic Resources (number) 26 66 33

Wetlands (acres) 205 205 251

Stream Crossings (number) 21 18 35

Floodplains (acres) 1,563 2,576 1,689

Parks & Wildlife Refuges (number) 25 19 30

Known Threatened and Endangered 

Species Habitats (number) 21 38 21

Notes:

 Best-Performing Corridor Alternative

 Moderately-Performing Corridor Alternative

 Worst-Performing Corridor Alternative

The I-75 Corridor Alternative is the Best-Performing Corridor Alternative overall. It rates as the BestPerforming Corridor Alternative for the most performance measures, including travel time, capital 

cost, use of existing transportation corridors, potential noise and vibration impacts, and potential 

impacts to known historic resources, wetlands, floodplains, and known threatened and endangered 

species habitats. It is the Moderately-Performing Corridor Alternative for ridership and stream 

crossings. The I-75 Corridor Alternative is not rated as the Worst-Performing Corridor Alternative for 

any of the distinguishing measures.
Chapter 6 Evaluation of Alternatives

Atlanta-Chattanooga HSGT Tier 1 DEIS 6-9 September 2016

The East Corridor Alternative rates as the Best-Performing Corridor Alternative in terms of potential 

impacts on wetlands and stream crossings, and rates as the Moderately-Performing Corridor 

Alternative with regard to travel time and potential impacts to known threatened and endangered 

species habitats. The East Corridor Alternative has greater noise-sensitive land uses than the I-75 

Corridor Alternative, but of the three Corridor Alternatives, it has the most vibration-sensitive land 

uses. The East Corridor Alternative performs least well among the Corridor Alternatives in the areas 

of ridership, capital cost, and potential impacts to known historic resources and floodplains.

The I-75/Rome Corridor Alternative rates as the Best-Performing Corridor Alternative for ridership 

and potential impacts to known threatened and endangered species habitats. It rates as the 

Moderately-Performing Corridor Alternative with regard to use of existing transportation corridors 

and potential impacts to known historic resources and it rates as the Worst-Performing Corridor 

Alternative for travel time, potential noise impacts, and potential impacts to wetlands and stream 

crossings.

The No-Build Alternative would not achieve the Project purpose as it would not reduce travel time or 

enhance passenger mobility throughout the Project Area between the metropolitan areas and 

airports of Atlanta and Chattanooga. The projects in the No-Build Alternative would incur costs and 

potential effects on the human and natural environment that would be determined by the sponsors of 

those projects. As the geographic scope and nature of the No-Build Alternative projects is limited, 

the potential effects of the projects are likely to be limited. While the No-Build Alternative has the 

potential to cause fewer effects on the human and natural environment than the Corridor

Alternatives, it would not improve air quality because it would not reduce the quantity or the growth 

rate of mobile source emissions resulting from vehicle miles traveled on the highway network in the 

Project Area.

The findings of this analysis indicate that the decision to be made by the Tier 1 EIS process involves 

examining the trade-offs between the benefits and effects of the Corridor Alternatives. Given GDOT 

and TDOT’s use of conservative buffer areas in this study, opportunity exists to avoid or minimize 

effects on the human and natural environment as the Project advances to Tier 2 study. For this 

reason, it may be more relevant to weight the cost-effectiveness criteria. In doing so, trade-offs 

remain.

If a Corridor Alternative is selected by this Tier 1 FEIS/ROD , FRA, GDOT, and TDOT would work to 

preserve existing and planned transportation operations in the existing corridors they affect as well 

as avoid or minimize impacts on the human and natural environments. In Tier 2, GDOT and TDOT

will coordinate with regulatory agencies to identify and refine alignments that avoid or minimize 

effects. Likewise, in the Tier 2 phase of the project, GDOT and TDOT will work with affected 

stakeholders and the communities to avoid or minimize effects of alignments it develops during Tier 

2 study. 

6.4 Next Steps

After FRA publishes the Tier 1 DEIS and the public comment period for the Tier 1 DEIS is 

completed, GDOT and TDOT will prepare a combined Tier 1 FEIS/Record of Decision (ROD), which 

will identify the Preferred Corridor Alternative. FRA, GDOT, and TDOT will evaluate potential 

alignments within the selected Preferred Corridor Alternative in the Tier 2 NEPA process.

Since there will be no selection of a preferred technology as part of this Tier 1 DEIS, both Maglev 

and steel-wheel train technologies advance for consideration with the Preferred Alternative and NoBuild Alternative. When a technology is selected, the selected alignment will be refined to optimize 

the operation of the selected technology.
Chapter 7 Coordination with Agencies, Stakeholders, and the Public

Atlanta-Chattanooga HSGT Tier 1 DEIS 7-1 September 2016

7.0 COORDINATION WITH AGENCIES, STAKEHOLDERS, 

AND THE PUBLIC 

In compliance with the Safe Accountable Flexible Efficient Transportation Equity Act: A Legacy for 

Users (SAFETEA-LU), Moving Ahead for Progress in the 21st Century Act (MAP-21), and the 

National Environmental Policy Act (NEPA), FRA, GDOT, and TDOT implemented a comprehensive 

program to coordinate with federal, state, and local agencies, and maximize participation of the 

many stakeholders and the public in the Project Area at key points in the environmental review 

process. The program allowed for dialogue on issues and alternatives and assisted in the 

development of solutions. This chapter describes coordination and the public involvement activities 

that were conducted as part of the Tier 1 DEIS for the Project.

7.1 Coordination Plan

Consistent with SAFETEA-LU, which calls for the development of a coordination plan for all projects 

for which an EIS is prepared under NEPA, GDOT, in coordination with TDOT and the FRA drafted a

Coordination Plan (GDOT 2010) and a Public Involvement Plan (PIP) (GDOT 2007). The 

Coordination Plan provided structure for coordination and communication between lead federal and 

state, cooperating, and participating agencies, including tribal governments, and was intended to 

guide the agency coordination process, make reviews more efficient, and streamline the project 

decision-making process. More specifically, the Coordination Plan outlined the activities that

occurred during the NEPA process to coordinate agency participation and comment. It was designed 

to provide flexibility to address changes to the Project. GDOT submitted the plan to potentially 

interested agencies for review and comment.

The PIP was developed to guide the public involvement process for Project. It is based on GDOT’s 

Public Involvement Guidelines (GDOT 2012) and is intended to ensure ongoing public involvement 

using a variety of tools and techniques to invite and encourage the public to learn about and become 

involved in the Project.

In 2014, GDOT merged the Coordination Plan and PIP into one document, covering both public, 

agency, and stakeholder involvement. The Agency and Stakeholder Involvement Plan (ASIP) carries 

forward the two previous documents through completion of the Tier 1 EIS, and includes revisions 

and updates in accordance with Section 6002 of Public Law 104-59 SAFETEA-LU and amended by 

Section 1305 MAP-21. The ASIP outlines activities, tools, and techniques used to maximize 

participation in the Project. See Appendix E for a copy of the ASIP.

7.2 Agency Coordination and Consultation

Section 6002 of SAFETEA-LU promotes efficient project management by lead agencies and 

enhanced opportunities for coordination with the public and other federal, state, local, and tribal 

government agencies during project development. When the Tier 1 DEIS was initiated, the FHWA 

and FRA served as co-Lead agencies for the Project. As such, the agency coordination and 

consultation was conducted in accordance with these requirements. GDOT, in coordination with 

FRA, FHWA, and the TDOT, prepared and mailed participating agency19 invitation letters to federal, 

state, and local government agency representatives. Note that in 2014, FHWA’s role changed from a 

Lead Agency to a participating agency. A full listing of these agencies is included in Appendix E, 

Agency Coordination & Public Outreach, of this Tier 1 DEIS. No agencies were invited to serve as a 

 

19 Participating agencies, as defined by SAFETEA-LU, are those with an interest in the project. FHWA was originally a Lead agency 

in co-operation with FRA for the project, but has since changed status to a Participating agency. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 7-2 September 2016

cooperating agency20. Outreach efforts to agencies affiliated with the project included agency 

scoping meetings, interagency coordination meetings, and participation in the Steering Committee, 

described in Section 7.2.3.

7.2.1 Agency Scoping

The environmental planning and review process for the Project began with early coordination and an 

agency scoping process. Federal, state, and local agencies received invitations to participate and 

provide comments regarding possible concerns or considerations for the resource areas under their 

authority. A copy of the invitation letter and mailing list are included in the Scoping Summary Report

(GDOT 2008) contained in Appendix E.

The scoping process began on August 22, 2007 and ended on October 4, 2007 during which two 

agency scoping meetings were held. The scoping process for the Project was conducted in 

accordance with 40 CFR 1501.7 to solicit participation from agencies, counties, municipalities, and 

the public as part of the NEPA process. The scoping process was used to identify the range of mode 

technologies and corridors to be studied, the potential impacts to the human and natural 

environments, and the key issues and concerns to be addressed in the Tier 1 EIS.

The Agency Scoping Meetings were announced in a Notice of Intent (NOI) that appeared in the 

Federal Register on August 22, 2007 (see Appendix A). State and federal environmental regulatory 

and review agencies, Native American tribal councils, municipalities, counties, and other government 

organizations and officials were notified of the Agency Scoping Meetings and scoping process 

through direct mailings, which also initiated the early coordination process. The locations, dates, and 

number of attendees at the Agency Scoping Meetings are outlined in Table 7-1.

Table 7-1: Agency Scoping Meetings

Location Date/Time Number of 

Attendees

GDOT Office of Environment/Location

3993 Aviation Circle, Atlanta, Georgia

September 18, 2007,

10:30 am - 12:00 pm 12

Chattanooga Hamilton County Bicentennial Library 

1001 Broad Street, Chattanooga, Tennessee

September 20, 2007, 

10:30 am - 12:00 pm 9

Each Agency Scoping Meeting opened with GDOT providing an overview of the Project, followed by 

a presentation outlining the scope of the Project. After the presentation, agency representatives 

could ask questions, provide input, or specify analysis for consideration in the EIS process. The 

Agency Scoping Meetings are summarized in the Scoping Summary Report in Appendix E.

Highlights of the feedback from the two Agency Scoping Meetings included comments pertaining to:

 Available capacity and use of active CSX and Norfolk Southern (NS) freight corridors;

 Potential effects on water and biological resources;

 The number and locations of stations and their limitations on potential train speed;

 The availability of preliminary Project cost figures;

 Consideration of other mode technologies;

 

20 A Cooperating Agency is any federal agency, other than a Lead Agency, that has jurisdiction by law or special expertise with 

respect to any environmental impact involved in a proposed project or project alternative (40 CFR 1508.5).
Chapter 7 Coordination with Agencies, Stakeholders, and the Public

Atlanta-Chattanooga HSGT Tier 1 DEIS 7-3 September 2016

 Integration of the Project with other transportation improvement projects already planned or 

underway; and

 The potential location of alignments and stations.

7.2.2 Interagency Coordination Meetings

Coordination meetings between federal and state lead agencies took place on a monthly basis

throughout the development of the Tier 1 DEIS. These meetings provided opportunity for ongoing 

coordination and discussion of the Project process, products, and issues. Also, in accordance with 

the ASIP, Participating Agency meetings were held to review the key Tier 1 NEPA milestones.

Participating agencies were involved in, and participated in the review of the following aspects of the 

Project: 

 Purpose and need;

 Identification of the potential corridors and mode technologies;

 Corridor screening and alternative development; and

 Scope of the environmental impact assessment of the Tier 1 DEIS.

7.2.3 HSGT Intermodal Sub-Committee

Formation of the HSGT Intermodal Sub-Committee supported the development of the Tier 1 DEIS. 

The Sub-Committee includes members of the of the Georgia State Transportation Board and study 

area stakeholders, which generally include County Commissioners, City Council members, and 

planning managers/staff of jurisdictions within the Project Area. The Intermodal Sub-Committee 

received regular briefings throughout the development of this Tier 1 DEIS and provided input to 

GDOT project management staff at key points.

7.3 Tribal Coordination

Since Native American Tribes may have interests regarding natural and cultural resources that could 

be in the Project Area, and in accordance with federal requirements, the following tribes and the 

Georgia Natural Heritage Program were contacted via letter during the scoping process:

Alabama-Quassarte Tribal Town Creek Nation, Muscogee (Creek) Nation,

Alabama-Coushatta Tribe of Texas, Muscogee (Creek) National Council, 

Cherokee Nation, Chickasaw Nation, Poarch Band of Creek Indians, 

Coushatta Tribe of Louisiana, Seminole Nation of Oklahoma, 

Eastern Band of Cherokee Indians, Seminole Tribe of Florida, 

Eastern Shawnee Tribe of Oklahoma, Shawnee Tribe, 

Kialegee Tribal Town of the Creek Nation, Thlopthlocco Tribal Town, 

United Keetoowah Band of Cherokee

FRA, GDOT, and TDOT will continue to consult with the tribes regarding potential natural and 

cultural resource impacts of concern to the tribes throughout Project development.

7.4 Stakeholder Involvement

Stakeholders were engaged on an ongoing basis to provide timely and ongoing feedback. 

Stakeholders were identified as any agency, organization, or group with an interest in the Project

that was not designated as a participating agency. A full list of stakeholders for the Project is 

provided in the ASIP (see Appendix E).
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Atlanta-Chattanooga HSGT Tier 1 DEIS 7-4 September 2016

7.4.1 Spring 2008 Stakeholder Meetings 

In the early stages of the Tier 1 DEIS, stakeholders were involved in developing the Project purpose 

and need, and identifying the range of potential mode technologies and corridors. As shown in Table 

7-2 during the months of January to June 2008, 19 meetings were held with local planning and 

technical staff in the Project Area. Meeting participants were provided an overview of the Project, 

profile sheets and typical sections of corridors under consideration. Potential alignments and station 

locations were discussed. The details of these meetings are outlined in the Final Technical Meeting 

Minutes (GDOT 2008). More than 60 local government representatives participated in these 

meetings. Highlights of the feedback from these meetings included comments pertaining to:

 The need to include local knowledge and opinions regarding the placement of stations and 

alignments;

 Areas suitable for the proposed HSGT service are often the same areas as those proposed for 

industrial-related economic development;

 Current county zoning ordinances may not be able to accommodate TOD;

 Land development activities currently underway for areas proposed for HSGT alignments;

 The effect an HSGT system would have on the local tax base, and concern it would have a 

negative economic effect;

 Concerns for access to businesses and residences along the alignments, effects to

Environmental Justice communities, visual resources, and historic and archaeological sites;

 Suggestion to tunnel sections of the HSGT alignment rather than have aerial sections, when 

necessary;

 Support of future connectivity to Nashville; and

 Potential for local matching funds for future phases of the Project.

In addition, from July to September 2008, over 20 supplemental stakeholder meetings were held 

with community, neighborhood, and business organizations. Information about the Tier 1 DEIS and 

the Project was available at each meeting. 
Chapter 7 Coordination with Agencies, Stakeholders, and the Public

Atlanta-Chattanooga HSGT Tier 1 DEIS 7-5 September 2016

Table 7-2: Spring 2008 Stakeholder Meetings

Stakeholder Location Date Number of 

Attendees

Douglas County Douglas County Courthouse

8700 Hospital Drive, Douglasville, GA January 23, 2008 2

City of Cartersville

Planning & Development Department

City Hall, 10 North Public Square, 

Cartersville, GA

January 23, 2008 7

Floyd County and City of Rome Planning Department, City of Rome 

601 Broad Street, Rome, GA January 24, 2008 7

City of Marietta Development Services Department

205 Lawrence Street, Marietta, GA January 24, 2008 3

Murray County

Murray County Land Development 

Office

121 North 4th Avenue, Chatsworth, GA

January 25, 2008 3

City of Atlanta

Atlanta City Hall

55 Trinity Avenue, Suite 1450, 

Atlanta, GA

January 25, 2008 2

Polk County

Planning & Zoning Commissioner's 

Office

144 West Avenue, Cedartown, GA

January 28, 2008 3

Catoosa County and City of Ringgold City of Ringgold Administrative Offices

150 Tennessee Street, Ringgold, GA January 28, 2008 4

Gordon County Gordon County Chamber of Commerce

300 South Wall Street, Calhoun, GA January 29, 2008 4

Bartow County

Bartow County Commissioner's Office

135 West Cherokee Avenue, Suite 135

Cartersville, GA

January 29, 2008 2

Cumberland Community Improvement 

District

240 Interstate North Parkway

Marietta, Georgia 30006 April 23, 2008 1

Town Center Community Improvement 

District

Town Park Commons, 

Bldg. 125, Town Park Drive

Marietta, Georgia 30066

April 23, 2008 1

Hamilton County, City of Chattanooga, 

Chattanooga-Hamilton County Regional 

Planning & Chattanooga-Hamilton, 

County/North Georgia TPO

1250 Market Street, 

Chattanooga, TN May 21, 2008 4

Chattanooga Metropolitan Airport 

Authority

101 Airport Road

Chattanooga, TN May 21, 2008 1

City of Rockmart 200 S Marble Street, Rockmart, GA May 22, 2008 2

Whitfield Count, City of Dalton, North 

Georgia Regional Development Center 

(NGRDC)

Administrative Building #1

301 West Crawford Street, 

Dalton, GA

May 23, 2008 8

Clayton County

Clayton County DOT

7960 N. McDonough Street

Jonesboro, GA

June 13, 2008 3

Cobb County 100 Cherokee Street, Marietta, GA June 19, 2008 5

Paulding County Henry Winn Building

120 East Memorial Drive, Dallas, GA June 19, 2008 2

7.4.2 Fall 2010 Stakeholder Meetings

To support the corridor screening and alternative development process, in fall 2010 several 

stakeholder meetings were held. Stakeholders were notified of meetings by mail or email notices two 

weeks prior to the meetings. Two days prior to the meetings, email reminders encouraged 

stakeholder attendance. These meetings are outlined in Table 7-3.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 7-6 September 2016

Table 7-3: Fall 2010 Stakeholder Meetings

Location Date/Time Number of 

Attendees

Atlanta-Fulton County Library/Margaret Mitchell Branch

1 Margaret Mitchell Square

Atlanta, GA 30303

October 26, 2010

10 AM – 12 Noon 4

Dalton City Hall

300 W. Waugh St.

Dalton, GA 30720

October 27, 2010

10 AM – 12 Noon 17

Cumberland/Town Center CID

240 Interstate North Parkway

Atlanta, GA 30339

October 28, 2010

1:30 PM – 3:30 PM 6

Cartersville Council Chambers

10 Public Square

Cartersville, GA 30120

October 28, 2010

10:30 AM – 12 Noon 6

Chattanooga City Council

1000 Lindsay Street

Chattanooga, TN 37402

October 29, 2010

10 AM – 12 Noon 19

Dalton Utilities Board Room

1200 VD Parrott Parkway

Dalton, GA 30720

November 2, 2010

7:30 AM – 9:00 AM 9

City Hall 

Mayor’s Conference Room 

City of Chattanooga 

November 4, 2010

4:00 PM – 5:30 PM 27

Sam King Room-City Hall

601 Broad Street 

Rome, GA 30161

November 8, 2010

3:00 PM – 4:30 PM 13

Dalton- Whitfield Chamber of Commerce

890 College Drive

Dalton, GA 30720

November 16, 2010

10 AM – 12 Noon 2

Highlights of the feedback from these stakeholder meetings included comments pertaining to:

 Right-of-way (ROW) requirements for an HSGT alignment, as well as the location of the potential 

alignments and stations, and the fare, frequency and schedule of train operations;

 Corridor alternatives removed from consideration;

 Implementation timeframe and funding mechanisms;

 Connectivity to other forms of transit;

 Historic resources and water resource impacts;

 Funding for HSGT projects nationwide and impacts on this Project;

 Emergency preparedness for a potential high-speed train crash; and 

 Whether proposed HSGT service along the I-75 corridor would lessen the need for future 

additional roadway capacity.

7.5 Public Involvement

To date, there have been two major decision points where significant involvement from the public 

was solicited. The first was at the public scoping meetings held in 2007 to get input on the purpose 

and need, the range of potential corridors, and the mode technologies to be evaluated in the Tier 1 

DEIS. The second was at a public information open house meeting held in 2010 to describe to the 

public the alternative development process and the results of the corridor screening.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 7-7 September 2016

7.5.1 Fall 2007 Public Scoping Meetings

The formal comment period for the scoping process began on August 22, 2007 and ended on 

October 4, 2007. Three Public Scoping Meetings were held for the Project during that time. Over 70 

people attended the Public Scoping Meetings. The Public Scoping Meetings were advertised in local 

newspapers such as the Atlanta Journal Constitution, the Rome-News Tribune, the Daily TribuneNews of Cartersville, and the Chattanooga Times-Free Press. Meetings were also announced on the 

Project website (http://www.dot.ga.gov/travelingingeorgia/rail/Pages/Atl-Chatt.aspx). The meetings 

are outlined in Table 7-4.

Table 7-4: Fall 2007 Public Scoping Meetings

Location Date/Time Number of 

Attendees

McEachern High School

2400 New Macland Road 

Powder Springs, GA

September 18, 2007 

5:00 – 7:30 pm 13

Rome Civic Center

400 Civic Center Drive

Rome, GA

September 19, 2007 

5:00 – 7:30 pm 14

Chattanooga Hamilton County Bicentennial Library

1001 Broad Street

Chattanooga, TN

September 20, 2007 

5:00 – 7:30 pm 49

Each of the Public Scoping Meetings followed the same format as the Agency Scoping Meetings in 

Section 7.2.1. At each meeting, attendees signed-in upon arrival and received a Scoping 

Information Package. Meetings included an “open house” area with a series of information boards 

displayed. The information boards illustrated the corridors under consideration and provided an 

overview of the EIS process. 

Each meeting opened with GDOT staff providing an overview of the Project, followed by a 

presentation outlining the scope of the Project. After the presentation, members of the public could 

ask questions and provide input. Members of the GDOT Project team were available to answer 

questions. Attendees had the option of either completing the comment form contained in the Scoping 

Information Package at the meeting or mailing it in prior to the close of the comment period. A court 

reporter was also present to record public comments. A record of all attendees and participants was 

compiled; individuals were added to the overall Tier 1 DEIS mailing list and database.

All public meeting locations were compliant with the ADA. The Scoping Summary Report (GDOT 

2008) details the comments and issues raised by the public during the Public Scoping Meetings.

Highlights of the feedback from these meetings included comments pertaining to:

 Potential alignments and station locations;

 Connections with existing and planned transit systems;

 Potential costs of the Project and the amount the government may have to pay per rider;

 Air quality benefits and reduced fuel consumption resulting from auto trip being replaced by the 

Project;

 the Project’s effect of positively transforming communities / land uses or leading to additional 

urban sprawl;

 the Project‘s potential for attracting investment in infrastructure, economic development, and 

capital investments to poor regions;

 Capacity concerns for Chattanooga Metropolitan Airport; and

 Concern for the potential adverse effects to cultural resources.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 7-8 September 2016

The information gathered during the scoping process was used to assess which Project mode 

technologies and corridors met the purpose and need while minimizing impacts to the social, 

cultural, and natural environments. Input gathered also assisted in identification of specific 

environmental impacts to be assessed in the Tier 2 NEPA process. 

7.5.2 Fall 2010 Public Information Open House Meetings 

GDOT conducted four public information open house meetings in the Project Area to provide 

opportunities for public review and comment on the corridor screening and alternative process, and 

results. The meetings were held between November 4, 2010 and November 18, 2010 and were

attended by over 200 individuals. A list of the public workshop meeting locations, dates, and number 

of attendees is provided in Table 7-5. 

Table 7-5: Fall 2010 Public Information Open House Meetings

Location Date/Time Number of 

Attendees

CHCRPA Regional Planning Agency

1250 Market Street (Room 1A, First Floor), Chattanooga, TN 

November 4, 2010 

6:00 - 8:00 pm 66

Dalton State College

650 College Drive (James Brown Center, Room 105)

Dalton, GA 

November 8, 2010 

6:00 - 8:00 pm 87

St. Mark United Methodist

781 Peachtree St. NE (Fellowship Hall), Atlanta, GA 

November 9, 2010 

6:00 - 8:00 pm 32

Cartersville Civic Center

435 W. Main Street

Cartersville, GA

November 18, 2010 

6:00 - 8:00 pm 28

At each meeting, attendees signed-in upon arrival and received an information package that 

included a Project newsletter with a Project description and maps, a comment card, and a copy of 

the presentation. Information was also provided in Spanish and Portuguese. The first portion of the 

meetings provided an opportunity for the attendees to view a series of display boards that provided 

an overview of the Tier 1 EIS process, as well as the corridor screening and alternative development 

processes. 

Each meeting opened with GDOT staff welcoming attendees, followed by a presentation that 

provided an update on the Project and an overview of the corridor screening and alternative 

development process, and the preliminary results. After the presentation, members of the public 

could ask questions and provide input. Members of the Project team were available to answer 

questions. Attendees had the option of either completing the comment form contained in the 

information package at the meeting or mailing it in prior to the close of the comment period. A record 

of all attendees and participants was compiled; individuals were added to the overall Tier 1 DEIS 

mailing list and database.

A court reporter was present to record the public’s comments. A summary of the comments received 

from the meetings is included in Appendix E. Highlights of the feedback from the meetings included 

comments pertaining to:

 A train technology preference;

 Support for the potential financial benefits and regional/national connectivity that could come 

from an HSGT system; and

 Concern for property acquisition and additional noise generated by HSGT.
Chapter 7 Coordination with Agencies, Stakeholders, and the Public

Atlanta-Chattanooga HSGT Tier 1 DEIS 7-9 September 2016

7.5.2.1 Public Information Open House Advertisement

Advertisement for the public information open house meetings appeared on the Project website, a 

Project flyer was distributed to those listed in the contact database, and notices were sent to 

chambers of commerce and other agencies in the Project Area. Table 7-6 gives the date and 

publication of the announcements for the open house meetings. 

Table 7-6: Public Information Open House Advertisement

Meeting Publication Date (2010)

Chattanooga, TN Chattanooga Times Free Press October 24, 25, 26

Dalton, GA The Daily Citizen October 31

Atlanta, GA Atlanta Journal Constitution October 28 and 31, November 1

Cartersville, GA Daily Tribune November 11, 12 and 14

Public service announcements were sent to local radio stations and meeting announcements were 

sent to online calendars (WABE, Access Atlanta, etc). Press releases were distributed to GDOT’s 

media contact list. The chambers of commerce in each city assisted in promoting the meetings by 

distributing flyers by email and posting on their websites. Meeting details were also posted on the 

Project website and the GDOT website.

7.5.2.2 Ongoing Agency Coordination

Additional agency coordination has been ongoing since the project started to keep agencies 

informed on the Project’s progress. The most recent coordination meeting was held in August 2013 

between FRA, FHWA, TDOT, and GDOT.

7.6 Public Meetings

During the public comment period for this Tier 1 DEIS, FRA, GDOT, and TDOT will hold public 

meetings. The Project Team has not yet determined how many meetings will be held or the where 

they will be held. The meetings will be an opportunity for FRA, GDOT and TDOT to hear comments 

on the Tier 1 DEIS. After the close of the public comment period, FRA, GDOT and TDOT will 

consider the public and agency input it has heard as well as the findings of the Tier 1 DEIS. The 

agencies will then select a Preferred Corridor Alternative from among the alternatives considered in 

the Tier 1 DEIS.

In accordance with MAP-21, FRA may issue a combined Tier 1 FEIS/ROD. The Tier 1 FEIS/ROD 

will identify the Preferred Corridor Alternative, summarize the environmental impacts, respond to 

public and agency comments received on the Tier 1 DEIS, and discuss the reasons why it was 

selected. During the development of the Tier 1 FEIS/ROD, GDOT and TDOT will also undertake 

additional public and agency coordination. GDOT will post the Tier 1 FEIS/ROD on the Project 

website (http://www.dot.ga.gov/IS/Rail/AtlantatoChattanooga), and publish notices in primary Project 

Area newspapers.

7.7 Communication Tools

GDOT and TDOT use a variety of communication tools to inform and solicit input from the public and 

agencies. Communication tools complimented and supplemented the outreach effort. These tools 

included:

 Stakeholder contact database;

 Project website and email;
Chapter 7 Coordination with Agencies, Stakeholders, and the Public

Atlanta-Chattanooga HSGT Tier 1 DEIS 7-10 September 2016

 Newsletters;

 Media relations; and

 Comment forms (available on the Project website and at all public meetings).

7.7.1 Stakeholder Contact Database

GDOT developed a stakeholder contact database, which expanded over the course of the Tier 1 

NEPA process. The database listed interested individuals and groups who desired to be kept 

informed of the progress of the Project, and aided in promoting participation at public meetings and 

notifying the public of key updates to the Project website. 

The database included over 400 individuals representing the public, property owners in the Project 

Area, agencies, elected and public officials, civic and community groups, public interest groups, 

faith-based organizations, and the business community. Updates to the stakeholder contact 

database were made throughout the development of the Tier 1 DEIS.

7.7.2 Project Website and Email

GDOT established a website for the Project at http://www.dot.ga.gov/IS/Rail/AtlantatoChattanooga to 

provide updated Project information during the Tier 1 NEPA process. The Project website includes a 

synopsis of the Project, frequently asked questions, Final Scoping Summary Report, and Existing 

Conditions Report.

7.7.3 Newsletters

GDOT and TDOT produced and distributed two newsletters at key milestones during development of 

the Tier 1 DEIS. A Project newsletter was produced in Spring 2008 and distributed to stakeholders 

and the public. Another newsletter coincided with the release of the results of the corridor screening 

and alternatives development process in Fall 2010. The newsletters shared information on these 

activities and findings, and encouraged public input. Distribution of newsletters electronically and in 

hard copy made the publications accessible to a large number of people. A copy of each newsletter 

is included in Appendix E.

7.7.4 Media Relations

Media coverage aided in advertising the Project and as a tool to encourage public participation in the 

development of the Tier 1 DEIS. The ASIP lists the media outlets used by GDOT during the process

including printed media, radio, television, colleges and universities, and community outlets.

7.7.5 Comment Forms

Comment forms in English, Portuguese, and Spanish languages were used during public outreach 

for the Project to solicit input from the public. When the Tier 1 DEIS document is available for public 

review during the public comment period, GDOT and TDOT will make comment forms available at 

public meetings and on the GDOT Project website 

(http://www.dot.ga.gov/IS/Rail/AtlantatoChattanooga).

7.7.6 Accommodations for Minority, Low-income, and Persons with 

Disabilities

Special outreach efforts were made to reach minority, low-income, and limited English proficiency 

(LEP) populations and persons with disabilities. Strategies to reach minority, low-income, and 

disabled populations included holding meetings in transit-accessible locations and at a variety of 

meeting times, including nights and weekends, in order to encourage maximum participation.

Spanish and Portuguese language interpreters were available at each meeting to assist LEP 
Chapter 7 Coordination with Agencies, Stakeholders, and the Public

Atlanta-Chattanooga HSGT Tier 1 DEIS 7-11 September 2016

populations. All public meeting locations were compliant with the Americans with Disabilities Act 

(ADA).
Chapter 8 References and Bibliography

Atlanta-Chattanooga HSGT Tier 1 DEIS 8-1 September 2016

8.0 REFERENCES AND BIBLIOGRAPHY

Access Atlanta. Available online at: http://www.accessatlanta.com/

Advisory Council on Historic Preservation (ACHP). 2011. Section 106 Fact Sheet. Available online 

at: http://www.achp.gov/OFAPFactSheet2011.pdf

ACHP. 2004. NHPA Section 106 (36 CFR Part 800 Protection of Historic Properties. August 5, 2004

AECOM. 2010. Cleveland-Bradley County Strategic Plan 25-Year Population, Housing and 

Employment Projections. Available online at: 

http://www.bcc2035.com/18435%20Cleveland%20Bradley%20Growth%2004.12.pdf

Archaeological Resources Protection Act of 1979 (ARPA). 16 U.S.C. 470aa-470mm; Public Law 96-

95. Available online at: http://www.nps.gov/archeology/tools/Laws/arpa.htm

Airports Council International (ACI). 2013. Airport Statistics and Data Centre. Available online at: 

http://www.aci.aero/Data-Centre

Atlanta Convention & Visitors Bureau. 2014. http://www.atlanta.net/acvb/

Atlanta Regional Commission (ARC). 2014. Conformity Determination Report. Available online: 

http://www.atlantaregional.com/environment/air/air-quality-planning

ARC. 2010. Plan 2040 Regional Transportation Plan. Atlanta, GA: Adopted June 22, 2011. Available 

online at: http://www.atlantaregional.com/plan2040

ARC. 2010. Bridging the Gap 2010: Investigating Solutions for Transportation Funding Alternatives 

in the Atlanta Region. Atlanta, GA. Available online at: 

http://www.atlantaregional.com/File%20Library/Transportation/Financing_Transportation/tp_fi

nance_alternatives_report_030510.pdf

ARC. 2009. ARC's Population and Employment Forecast. Available online at: 

http://www.atlantaregional.com/info-center/forecasts

ARC. 2006. Envision6 2030 Regional Transportation Plan. Atlanta, GA: May 2006. Available online 

at: 

http://atlantaregional.com/File%20Library/Transportation/Transportation%20Plans/tp_e6need

sassess_050106.pdf

ARC. 2002. Atlanta to Chattanooga Maglev Deployment Study Phase II Addendum. Atlanta, GA: 

March 2002.

ARC. 2002.Atlanta to Chattanooga Maglev Deployment Study Phase II, March 2002

ARC. 2000. Atlanta to Chattanooga Maglev Deployment Study and Project Description, June 2000

Bald and Golden Eagle Protection Act (BGEPA). 1940. (16 U.S.C. 668-668c) 

Beise, B. 2014. “Why Chattanooga?” in CityScope. Available online at:

http://www.cityscopemag.com/why-chattanooga/

Catoosa County Recreation Department. 2014. Recreation Facilities. Available online at: 

http://www.catoosarec.com/facilities.html

Chattanooga Area Regional Transportation Authority (CARTA). 2014. CARTA website. Available 

online at: http://www.carta-bus.org/

Chattanooga-Hamilton County Regional Planning Agency (CHCRPA). 2014. Chattanooga Hamilton 

County North Georgia Long-Range Transportation Plan, Volume 1 2040 LRTP Update. 

Available online at: http://www.chcrpa.org/2040RTP/CHCRPA_2040RTP_Vol-1.pdf
Chapter 8 References and Bibliography

Atlanta-Chattanooga HSGT Tier 1 DEIS 8-2 September 2016

CHCRPA. 2010. 2035 Long-Range Transportation Plan. Chattanooga, TN. Available online at:

http://www.chcrpa.org/TPO_reorganized/Plans_and_Programs/LRTP.htm

CHCRPA. 2010. Chattanooga Urban Area Transportation Improvement Program. Available online 

at: http://www.chcrpa.org/TPO.htm.

CHCRPA. 2005. Comprehensive Plan 2030, A Strategy for Growth. Available online 

at:http://www.chcrpa.org/Divisions_and_Functions/Comprehensive_Planning/Land_Use_Pla

nning/Land_Use_Planning-CompPlan2030.htm.

CHRPA. 2004. Downtown Plan Chattanooga 2025. Available online at:

http://www.chcrpa.org/Projects/Land_Use_Plans/Downtown%20Plan%20Chattanooga%202

025%20(2004)/Downtown_Plan_Chattanooga_2025(2006)A-F.htm

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0

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Chapter 9 Acronyms

Atlanta-Chattanooga HSGT Tier 1 DEIS 9-1 September 2016

9.0 ACRONYMS

ACHP Advisory Council on Historic Preservation

ADA Americans with Disabilities Act

ADT Average Daily Traffic

APC Air Pollution Control 

APM Automated People Mover

ARC Atlanta Regional Commission 

ASIP Agency and Stakeholder Involvement Plan

BACT Best Available Control Technologies 

BGEPA Bald and Golden Eagle Protection Act

CAA Clean Air Act of 1970 

CAAA Clean Air Act Amendments of 1990

CARTA Chattanooga Area Regional Transportation Authority 

CCKY Chattooga and Chickamauga Railway 

CCT Cobb Community Transit

CE Categorical Exclusion

CEQ Council on Environmental Quality

CFR Code of Federal Regulations

cfs cubic feet per second

CHCRPA Chattanooga-Hamilton County Regional Planning Agency

CMA Chattanooga Metropolitan Airport 

CMAQ Congestion Mitigation and Air Quality Improvement Program

CO Carbon monoxide

CR County Road

CSX Chessie-Seaboard Express Railroad Transportation

CTP Comprehensive Transportation Plan

CWA Clean Water Act

dB decibel

DEIS Draft Environmental Impact Statement 

DFIRM Digital Flood Insurance Rate Map

DMU Diesel Multiple Unit

DNR Department of Natural Resources

DOT Department of Transportation 

EA Environmental Assessment

EIS Environmental Impact Statement

EJ Environmental Justice

EPD Environmental Protection Division (of the Georgia Department of Natural Resources)

ESA Endangered Species Act

FD Final Design
Chapter 9 Acronyms

Atlanta-Chattanooga HSGT Tier 1 DEIS 9-2 September 2016

FEIS Final Environmental Impact Statement 

FEMA Federal Emergency Management Agency 

FHWA Federal Highway Administration 

FONSI Finding of No Significant Impact

FRA Federal Railroad Administration 

FRUTS Floyd-Rome Urban Transportation Study

FY Fiscal Year

GDNR Georgia Department of Natural Resources

GDOT Georgia Department of Transportation 

GCT Gwinnett County Transit

GEPA Georgia Environmental Policy Act

GHBS Georgia Historic Bridge Survey 

GIS Geographic Information Systems

GNHP Georgia Natural Heritage Program 

GO General Obligation

GRTA Georgia Regional Transportation Authority

GWQC Georgia Water Quality Control

HCP Habitat Conservation Plan

HJAIA Hartsfield-Jackson Atlanta International Airport 

HSGT High-Speed Ground Transportation 

HSIPR High Speed and Intercity Passenger Rail 

HSR High Speed Rail 

HUC Hydrologic Unit Codes

I-24 Interstate 24 

I-75 Interstate 75 

I-285 Interstate 285

I-85 Interstate 85

LEP Limited English Proficient

LWCF Land & Water Conservation Fund 

LOS Level of Service 

LRTP Long Range Transportation Plan

Maglev Magnetic Levitation 

MAP-21 Moving Ahead for Progress in the 21st Century Act

MARTA Metropolitan Atlanta Rapid Transit Authority

MMPT Multi-modal Passenger Terminal

MOE Measure of effectiveness

mph Miles per hour

MPO Metropolitan Planning Organization 

MS4s Municipal Separate Storm Sewer Systems

MSAT Mobile Source Air Toxics 
Chapter 9 Acronyms

Atlanta-Chattanooga HSGT Tier 1 DEIS 9-3 September 2016

NAAQS National Ambient Air Quality Standards 

NAGPRA Native American Graves Protection and Repatriation Act

NAHRGIS Natural, Archaeological Historical Resources Geographic Information Systems 

NEPA National Environmental Policy Act 

NFIP National Flood Insurance Program

NGRDC North Georgia Regional Development Center 

NHPA National Historic Preservation Act

NO2 Nitrogen Dioxides

NOx Nitrogen Oxides

NOI Notice of Intent

NPDES National Pollutant Discharge Elimination System 

NPS National Park Service

NRCS National Resources Conservation Service

NRHP National Register of Historic Places 

NWI National Wetlands Inventory (of the United States Fish and Wildlife Service)

NS Norfolk Southern 

O

3 Ozone

O&M Operating and Maintenance

P3s Public Private Partnerships

Pb Lead

PE Preliminary Engineering

PIP Public Involvement Plan

PM Particulate Matter

PM2.5 Particulate matter with a diameter of 2.5 micrometers and smaller

PM10 Particulate matter with a diameter of 10 micrometers and smaller

ppm parts per million

PRIIA Passenger Rail Investment and Improvement Act

Q3 Quadrangle 3 

RIBITS Regulatory In-lieu Fee and Bank Information Tracking System

ROD Record of Decision 

ROW Right-of-way

RRIF Railroad Rehabilitation and Improvement Financing 

RTD Rome Transportation Department

RTP Regional Transportation Plan

SAFETEA-LU Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users 

SC Southern Crescent

SCC Standard Cost Categories

SHPO State Historic Preservation Office 

SIP State Implementation Plan

SOx Sulfur Oxides
Chapter 9 Acronyms

Atlanta-Chattanooga HSGT Tier 1 DEIS 9-4 September 2016

SR State Route

STIP State Transportation Improvement Program

STP Surface Transportation Program

SWTP Statewide Transportation Plan

TAG Tennessee, Alabama and Georgia Railroad Line

T.C.A. Tennessee Code Annotated

TCP Traditional cultural property 

TDEC Tennessee Department of Environment and Conservation

TDOT Tennessee Department of Transportation

TEA-21 Transportation Equity Act for the 21st Century

TIFIA Transportation Infrastructure Finance and Innovation Act 

TIGER Topologically Integrated Geographic Encoding and Referencing 

TIGER Transportation Investment Generating Economic Recovery

TIP Transportation Improvement Program

TOD Transit-oriented development 

TVA Tennessee Valley Authority

US United States

USACE United States Army Corps of Engineers

USC United States Code

USDA United States Department of Agriculture

USDOI United States Department of the Interior

USDOT United States Department of Transportation 

USEPA United States Environmental Protection Agency 

USFS United States Forestry Service

USFWS United States Fish and Wildlife Service 

USGS United States Geological Survey

VHS Very High Speed 

W&A Western and Atlantic Railroad
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-1 September 2016

10.0 GLOSSARY OF TERMS

100-year floodplain – Areas along or adjacent to rivers, streams, or other bodies of water that 

convey floodwaters during a 100-year frequency storm event.

accessibility – A measure of how reachable locations or activities are from a given site; it is

influenced by changes in travel time, safety, vehicle operating costs, and transportation choice.

adverse effect – Defined in Section 106 of the National Historic Preservation Act (NHPA) (36 CFR 

800.5(a) (1)). An adverse effect to a historic property occurs when the project under consideration 

alters any characteristic that qualifies the property for inclusion in the National Register of Historic 

Places in a manner that would diminish the integrity of the property.

affected environment – Ambient conditions at the time an Environmental Impact Statement is

prepared.

Agricultural and Forestal District (AFD) – Provides a means to conserve, protect, and encourage 

the development and improvement of agricultural and forestal lands for the production of food and 

other agricultural and forestal products, and conserve and protect agricultural and forestal lands as 

valued natural and ecological resources which provide essential open spaces for clean air sheds, as 

well as for aesthetic purposes.

alighting(s) – The act of a passenger disembarking from a transit vehicle; see boarding(s)

alignment – The ground plan of a roadway, railway or other fixed route.

ambient air – A physical and chemical measure of the existing concentration of various chemicals in 

the outside air, usually determined over a specific time period (e.g., one hour, eight hours).

ambient background noise – The existing cumulative noise that is characteristic of an area based 

on current activity levels.

Archaeological Resources Protection Act of 1979 (ARPA) – governs the excavation 

of archaeological sites on federal and Indian lands in the united states, and the removal and 

disposition of archaeological collections from those sites

Area of Potential Effect (APE) – For purposes of complying with Section 106 of the NHPA, a

geographic area or areas where an undertaking (e.g., the Atlanta-Chattanooga HSGT project) may 

directly or indirectly cause alterations in the character or use of historic properties, if any such 

properties are located in the area of the project.

at-grade – level with the ground surface.

Atlanta Regional Commission (ARC) – The Atlanta Regional Commission (ARC) is the regional 

planning and intergovernmental coordination agency for the 10-county area including Cherokee, 

Clayton, Cobb, DeKalb, Douglas, Fayette, Fulton, Gwinnett, Henry and Rockdale counties, as well 

as the City of Atlanta.

Average Daily Traffic (ADT) - The total traffic volume during a given time period, ranging from 2 to 

364 consecutive days, divided by the number of days in that time period, and expressed in vehicles 

per day.
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-2 September 2016

Best Management Practices – Specific standards utilized during construction and design to 

minimize the impact on surrounding resources.

boarding(s), passenger – The count of passengers embarking onto a transit vehicle or route for the 

purposes of measuring ridership or fare revenue.

capital costs – The cost to construct a transportation system such as HSGT. Costs include design 

fees, vehicle procurement, environmental mitigation, property acquisition, construction materials, 

and labor for the construction of a project.

census tract – A small statistical subdivision of a county defined by a local committee of census 

data users for the purpose of presenting census information every ten years. The census tract 

boundaries, which are nested within counties, generally follow visible features and governmental unit 

boundaries.

centerline – The line corresponding to the central geometric axis of a railroad track, road, trail or 

other transportation corridor. It is typically used as the reference point for measurements of track 

dimensions and location.

Clean Air Act of 1970 (CAA) – Legislation mandating the U.S. Environmental Protection Agency 

(EPA) to set national air quality standards to protect the public against common pollutants. State 

governments are required to devise clean-up plans to meet these EPA standards.

Clean Air Act Amendment of 1990 (CAAA) – A strategy for the U.S. to address the problem of

urban smog. It requires states and the federal government to reduce emissions from automobiles, 

trucks, buses, ships, barges, and consumer products, and to meet air quality standards. It 

particularly addresses the urban problem of ozone, carbon monoxide (CO), and particulate matter. It 

defines how areas are designated “attainment” and allows the EPA to classify “non-attainment” 

areas as those that do not meet the federal air quality standards.

Corridor Alternative – A corridor alternative being evaluated as the proposed action during the EIS 

process.

cross section – The cross-sectional configuration of a transportation corridor (railway, trail, 

roadway, etc.) that specifies typical widths for tracks/travel lanes, related facilities, buffer areas and 

total right-of-way.

Comprehensive Plan – A plan required by state law to be used by local municipalities as a guide to 

decision-making about the natural and built environment.

commuter rail – A mode of passenger transportation where either diesel or electric-powered 

locomotives and their associated rail cars use tracks that are part of a general rail network.

Commuter rail is distinguished from intercity rail in the relatively smaller geographic scope of service 

area.

Conformity – A designation given to transportation plans, programs, and projects that conform to 

federally mandated state air-quality plans.

Congestion Mitigation and Air Quality (CMAQ) – Authorized under the Intermodal Surface

Transportation Equity Act (ISTEA), this law provided $6 billion in funding for surface transportation 

and other related projects that contribute to improvements in air-quality and reduce congestion.

Section 1101 of MAP-21 authorizes funds for the CMAQ program and Section 1105 amends 23 

U.S.C. 104(b)(4) and provides for the apportionment of funds.
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-3 September 2016

Council on Environmental Quality (CEQ) – Established in the Executive Office as part of the

National Environmental Policy Act of 1969 (NEPA), the council coordinates federal environmental 

efforts, policies, and initiatives, and ensures that federal agencies meet NEPA requirements.

cumulative impact – The impact on the environment which results from the incremental impact of 

the action when added to other past, present, and reasonably foreseeable future actions.

day-lighting – pedestrian safety measure achieved by removing parking spaces adjacent to curbs 

around an intersection, increasing visibility for pedestrians and drivers and minimizing conflicts

decibel – A unit of measure of sound pressure used to describe the loudness of sound on the 

A-weighted scale.

determination of eligibility – The decision made by the State Historic Preservation Office (SHPO) 

regarding whether historic buildings or districts are eligible for listing or listed in the National Register 

of Historic Places (NRHP).

direct effects – Effects that occur as a direct result of the project.

double-track – The construction of two (usually parallel) transit lines for the purpose of enhancing 

the efficiency of operations.

Draft Environmental Impact Statement (Draft EIS) – A comprehensive study of potential

environmental impacts related to federally assisted projects. Projects for which a DEIS is required 

are defined in the National environmental Policy Act of 1969, as amended.

effects – Synonymous with impact, includes the result from actions that may have a beneficial or 

detrimental outcome.

endangered species – A species whose prospects for survival are in immediate danger based on a 

loss of habitat, over-exploitation, predation, competition, or disease. An endangered species 

requires immediate attention or extinction will likely follow.

Environmental Justice (EJ) – Provides for equal protection from environmental hazards and fair 

treatment for all people regardless of race, ethnicity, or economic status, with respect to the

development, implementation, and enforcement of environmental laws, regulations, and policies. 

Fair treatment implies that no population of people bear an unequal share of negative environmental 

impacts of pollution or environmental hazard resulting from industrial, municipal, and commercial 

operations or the execution of federal, state, or local policies.

Federal Highway Administration (FHWA) – As part of the United States Department of

Transportation (USDOT), the FHWA is charged with the broad responsibility of ensuring that

America’s roads and highways continue to be safe and technologically up-to-date.

Federal Railroad Administration (FRA) – Created by the Department of Transportation Act of

1966 (49 U.S.C. 103, Section 3(e)(1)). Its purposes are to enforce regulations, administer railroad 

assistance programs, and conduct research and promote rail safety.

freight rail – A mode of freight transportation where either diesel or electric-powered locomotives 

and their associated rail cars use tracks that are part of a general rail network.

Final Environmental Impact Statement (FEIS) – The document is published following a Draft 

Environmental Impact Statement (DEIS). It addresses revisions in the design of the proposed 
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-4 September 2016

project, incorporates public and agency comments received during the public circulation period of 

the DEIS and during the DEIS public meeting, and identifies the Preferred Corridor Alternative.

Geographic Information Systems (GIS) – A system of computer software and hardware, data, and 

personnel to manipulate, analyze and present geographically referenced information or data that is 

identified according to their locations.

Georgia Department of Transportation (GDOT) – The Georgia Department of Transportation 

plans, constructs, maintains and improves Georgia’s road and bridges. The Department also 

provides support for other modes of transportation such as freight and intercity passenger train 

service, mass transit and airports, and airport and air safety planning. 

Georgia Natural Heritage Program (GNHP) - state-run program that inventories the occurrences 

and status of rare plant and animal species and native communities in the state.

grade crossing – An intersection where a roadway crosses a railway at the same elevation.

greenspace – general term describing an area of parkland, open space or other type of natural or 

vegetated land.

habitat – The area or environment where an organism or ecological community normally lives or

occurs.

high-level platforms – Station platforms constructed at the same level as a typical train-floor, 

approximately four feet above ground. Done to increase passenger boarding and alighting speeds

and to comply with the Americans with Disabilities Act. 

High Speed Ground Transportation (HSGT) – High Speed Ground Transportation is a mode of 

transportation that travels at greater speeds than traditional rail technology. The FRA defines HSGT 

as having the ability to travel at a speed of greater than 110 mph. For the purposes of this Project, 

HSGT is defined as having the ability to travel at speeds at or above 180 mph. The technology is 

most often used to move passengers rather than freight, and is a self-guided intercity passenger 

transportation mode that is time-competitive with air and auto for trips of 100 to 500 miles in length.

hydric soils – A soil that formed under conditions of saturation, flooding or ponding long enough

during the growing season to develop anaerobic conditions in the upper part.

hydrology indicators – The presence of water at or near the surface for a designated amount of 

time.

hydrophytic vegetation – Plant-life that thrives in wet conditions.

infill –The process of developing vacant or under-used parcels within existing urban areas that are 

already largely developed

intercity – traveling between two cities

Jurisdictional determination (JD) – Regulatory review of previously identified wetlands and waters 

of the United States Army Corp of Engineers (USACE) in compliance with Section 404 of the Clean 

Water Act.

land use – Classification providing information on land cover and the types of human activity

occurring on a parcel of land, such as “commercial,” “industrial,” “residential,” or “open space.”
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-5 September 2016

level of service (LOS) – A letter grade designation used to describe given roadway conditions with 

“A” being at or close to free-flow conditions and “F” being at or close to over-saturation of the 

roadway; usually based on the progression of vehicles through the green phase of a signal, driver 

discomfort/frustration, lost travel time, and fuel consumption.

low-income – Any household with income at or below the U.S. Bureau of the Census poverty

thresholds.

Magnetic Levitation (Maglev) – a system of transportation that suspends, guides and propels 

vehicles, predominantly trains, using magnetic levitation from a very large number of magnets for lift 

and propulsion.

Moving Ahead for Progress in the 21st Century (MAP-21) - Signed into law Public Law 112-141,

provides funds for surface transportation programs.

Metropolitan Atlanta Rapid Transit Authority (MARTA) – The principal rapid transit system in the 

metropolitan Atlanta region.

mass transit – Transportation that provides regular and continuing general or special transportation 

to the public; does not include school buses, charters, or sightseeing transportation.

master plan – An exhaustive plan that defines an airport’s short- and long-term development needs.

Metropolitan Planning Organization (MPO) – The forum for cooperative transportation decision

making for a metropolitan area. Title 23 U.S.C. §134 requires that (1) a MPO be designated for each 

Urbanized Area (UZA) containing 50,000 or more persons based on the latest US Census, and (2) 

the metropolitan area has a continuing, cooperative and comprehensive transportation planning 

process.

micron – A unit of length equal to one millionth (10-6) of a meter.

minority – A member of the following races: (1) Black or African American, (2) American Indian or 

Alaska Native, (3) Asian, (4) Native Hawaiian or other Pacific Islander, (5) Hispanic or Latino Origin.

mitigation – The actions necessary to reduce or eliminate an impact and thereby restoring the

affected environment and personnel to manipulate, analyze and present geographically referenced 

information or data that is identified according to their locations.

mitigation banking – The restoration, creation, enhancement, and preservation of wetlands and/or 

other aquatic resources, for the purpose of providing compensatory mitigation in advance of 

authorized impacts to similar resources.

multi-family – A classification of housing where multiple separate housing units for residential (i.e. 

non-commercial) inhabitants are contained within one building.

National Environmental Policy Act of 1969 (NEPA) – Requires federal agencies to consider the 

environmental impacts of major federal projects or decisions, to share information with the public; to 

identify and assess reasonable alternatives; and to coordinate efforts with other planning and 

environmental reviews taking place.

Native American Graves Protection and Repatriation Act (NAGPRA) - requires federal 

agencies and institutions that receive federal funding to return Native American" cultural items" to 
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-6 September 2016

lineal descendants and culturally affiliated Indian tribes and Native Hawaiian organizations. Cultural 

items include human remains, funerary objects, sacred objects, and objects of cultural patrimony.

National Historic Preservation Act (NHPA) - Legislation intended to preserve historical 

and archaeological sites in the United States of America. The act created the National Register of 

Historic Places, the list of National Historic Landmarks, and the State Historic Preservation Offices.

National Register of Historic Places (NRHP) – A federal list of buildings, sites, district or other

properties that have a historic significance. The National Register of Historic Places is maintained by 

the Keeper of the National Register.

No-Build Alternative – The future condition of an area in the absence of a project; assumes that no 

improvements will be made with the exception of periodic maintenance and minor enhancements 

needed to maintain safe operation and those already designated in the approved plan.

Norfolk Southern Railway (NS) – A national freight rail company operating within the study 

corridor.

off-peak period – Used to describe times where travel is not at its peak, or highest level, during the 

day. Off-peak travel usually occurs in the midday and evenings in most cities.

operating costs – The periodic and usual expenses a company incurs to generate revenues.

park-and-ride facility – A parking facility that is part of a transportation facility; an access mode for 

patrons to drive private vehicles to a transportation facility.

Passenger Rail – A passenger railroad service that operates between cities on trackage that is

usually part of the general railroad system.

Project Area – The special limits within which alternatives are considered.

Record of Decision (ROD) – A formal decision made by a lead federal agency based on its

interpretation of a Final Environmental Impact Statement.

ridership – The number of people using a public transportation system during a given time period.

river basin – The entire geographical area drained by a river and its tributaries.

right-of-way (ROW) – Land available for operation of transportation facilities (roadways or rail lines). 

The land is typically government-owned (local, state, or federal). A transportation facility may occupy 

all or a portion of the right-of-way. ROWs can be grade-separated or at-grade.

scoping – The effort taken at the beginning of a study to consider all issues that should be

addressed in the study. It is the first phase of activity to prepare an Environmental Impact Statement.

grade-separated – Used to describe an alignment that is elevated or below ground, or crossings 

that use an overpass or an underpass. Grade separation allows traffic or transit vehicles to pass 

stopping for opposing traffic on the crossed facilities.

ground-borne vibration and noise – The vibration-induced levels that propagate over ground

between the source and a receptor such as a building; typically assessed indoors.
Chapter 10 Glossary of Terms

Atlanta-Chattanooga HSGT Tier 1 DEIS 10-7 September 2016

secondary impact – The effect of an action that takes place sometime after a primary event has 

occurred.

single-family – Land use characterized by lots containing individual residential homes surrounded 

by yards.

State Historic Preservation Office (SHPO) – A state administrative agency responsible for carrying 

out consultation in accordance with the National Historic Preservation Act of 1966, as amended and 

other state historic preservation regulations.

steel-wheeled – The most common type of transit, characterized by that form of wheel on 

locomotives running along steel rail. 

stormwater – Runoff water that is generated by a rain event. Storm water discharges include runoff 

from land, pavements, building rooftops and other surfaces. Storm water runoff can accumulate a 

variety of pollutants such as oil and grease, chemicals, nutrients, metals, and bacteria as it travels 

across land before discharging into surface and other receiving waters. Heavy surges in storm water 

runoff can cause other negative effects, including flooding and erosion, to streams and adjacent lowlying areas, especially in urbanized watersheds.

Tier 1 Environmental Impact Statement (EIS) – A written statement, required by Section 102 (2) 

(C) of the NEPA for projects that involve a federal action such as funding. The Tier 1 EIS serves to 

provide information about significant environmental impacts and informs decision-makers and the 

public of practical alternatives that would prevent or minimize adverse impacts or improve the quality 

of the human environment.

threatened species – A species that may become endangered if surrounding conditions begin or 

continue to deteriorate.

topography – The surface features of a place or region.

Tennessee Department of Transportation (TDOT) – A multimodal agency with statewide 

responsibilities in aviation, public transit, waterways and railroads. The mission of TDOT is to plan, 

implement, maintain and manage an integrated transportation system for the movement of people

and products, with emphasis on quality, safety, efficiency and the environment.

wetlands – Tidal areas or swamps with water saturated soil characteristics and associated

vegetation that meet certain criteria on which filling and development are federally- and/or state -

regulated.
Chapter 11 List of Preparers

Atlanta-Chattanooga HSGT Tier 1 DEIS 11-1 September 2016

11.0 LIST OF PREPARERS

Public Agency Staff

Federal Railroad Administration

John Winkle

Environmental Protection Specialist

Catherine Dobbs

Environmental Protection Specialist

Wendy Messenger

Environmental Protection Specialist

David Valenstein

Division Chief, Environment & Systems Planning

Jessie Fernandez-Gatti

Community Planner

Georgia Department of Transportation

Glenn Bowman, P.E.

Director of Engineering

Carol L. Comer

Director, Division of Intermodal

Gail A. D’Avino, PhD

Environmental Services

Harry Boxler, AICP

Passenger Rail Projects, Intermodal Programs 

Consultant Team 

AECOM

Ken Bechely, P.G.

Responsibilities: Geological Resources

Christine Bishop-Edkins, AICP

Responsibilities: QA/QC Review

Scott Brown

Responsibilities: GIS, Tier 1 DEIS Preparation

Samantha Castro, CNU-A, LEED Green 

Responsibilities: Graphics/Document 

Coordination 

Louis Costa

Responsibilities: Alternatives Considered, 

Evaluation of Alternatives

Robert Dall

Responsibilities: Cost Estimating

Cesar DeRose, P.E.

Responsibilities: Capital Costs

Shelly Fialkoff

Responsibilities: Project Management, Tier 1 DEIS 

Preparation

Mark Gander, AICP

Responsibilities: Real Estate Cost Estimate

Joshua Gillespie, LEED AP

Responsibilities: Tier 1 DEIS Preparation

Christy Grier

Responsibilities: Tier 1 DEIS Preparation

John Jolly

Responsibilities: Geological Resources

Tim Kassa

Responsibilities: Tier 1 DEIS Preparation

Adelee Le Grand, AICP

Responsibilities: Project Management, Tier 1 DEIS 

Preparation

Mark Lippert, AICP

Responsibilities: Graphics, GIS

Eddie McFalls, P.E.

Responsibilities: Purpose and Need, Alternatives 

Considered, Section 4(f) and 6(f), Costs and 

Funding

Jeff Morrison

Responsibilities: Geological Resources

Michael A. Perrotta, PE

Responsibilities: Alternatives Considered
Chapter 11 List of Preparers

Atlanta-Chattanooga HSGT Tier 1 DEIS 11-2 September 2016

Ron Reitman, AICP

Responsibilities: Alternatives Considered

Janide Sidifall

Responsibilities: Agency, Stakeholder, and 

Public Coordination

Sinan Sidharoy

Responsibilities: GIS, Document Preparation

Brian C. Smart

Responsibilities: No-Build Alternative, 

Floodplains, Environmental Justice

Christopher Taylor, P.E.

Responsibilities: Capital Costs, Minimum 

Operable Segment

Commonwealth Research Associates

Chris Brady

Responsibilities: Agency Coordination and 

Stakeholder Outreach

Linda Hamrick

Responsibilities: Agency Coordination and 

Stakeholder Outreach

Dovetail Consulting

Mignon Allen

Responsibilities: Public Involvement and 

Stakeholder Outreach

Economic Development Research Group 

(EDR)

Responsibilities: Development Impact Analysis

Lisa Petraglia

Glen Weisbrod 

HNTB

Responsibilities: Financial Analysis, Funding 

Kirsten Berry

Claudia Bilotto, AICP

Randy Wade

Moreland Altobelli Associates, Inc.

Howard Stein Hudson

Responsibilities: Public Involvement and 

Stakeholder Outreach

Christopher Byrne

Maura Fitzpatrick

Ryan Walsh 

Huntley Associates

Responsibilities: Economic Development Impact 

Analysis

Richard W. Padgett

Jacobs (formerly Jordan, Jones & 

Goulding)

Responsibilities: Air Quality, Parklands, 

Communities, Hazardous Materials, 

Environmental Justice

Kalanos Johnson

Pat Smeeton

Kennedy Engineering & Associates

Lenor M. Bromberg, PE, AVS, LEEDR AP 

Responsibilities: Ecology Analysis

Laura Dawood

Responsibilities: Ecology Analysis

Katheryn N. Ferrall-Graff

Responsibilities: Ecology Analysis

Bruce D. Hart

Responsibilities: Ecology Analysis

Collin T. Lane

Responsibilities: Ecology Analysis

Timothy A. Nichols

Responsibilities: Ecology Analysis

Malvada

Miriam Cummings

Responsibilities: Public Involvement and 
Chapter 11 List of Preparers

Atlanta-Chattanooga HSGT Tier 1 DEIS 11-3 September 2016

Stakeholder Outreach

Bill W. Allen, P.E., AICP

Responsibilities: Land Use 

Robert Harbin

Responsibilities: GIS

G. Todd Hill, PP, AICP Responsibilities:

Executive Summary, Floodplains, Water Quality, 

Relocations, Section 4(f) and 6(f)

L.N. Manchi, P.E.

Responsibilities: Project Coordination, 

Transportation

Karla Poshedly

Responsibilities: No-Build Alternative, Travel 

Demand, and Transportation

New South Associates

Responsibilities: Historic and Archaeological 

Resources

Robbie D. Jones

J.W. Joseph, PhD, RPA

Scot Keith, RPA

PB Americas

Responsibilities: Vehicle Technology Modeling 

and Simulation, Noise and Vibration, Operation 

and Maintenance Costs

Steve Wolf

Viktoriya Yanitskaya

S.L. King & Associates

Responsibilities: Vehicle Storage and 

Maintenance Facilities

Theodore Georgacopoulos, P.E.

Ellen Keys Shellabarger

Michael Smith, P.E., LEED AP

Steer Davies Gleave (formerly Charles 

River & Associates)

Responsibilities: Travel demand 

modeling/forecasting

Jon Bottom
APPENDIX B: 

PUBLIC AND AGENCY INVOLVEMENT 

SUMMARY REPORT
ATLANTA-CHATTANOOGA

HIGH SPEED GROUND TRANSPORTATION PROJECT

TIER 1 DEIS PUBLIC AND AGENCY 

INVOLVEMENT SUMMARY REPORT

Prepared by:

Federal Railroad Administration (FRA)

Georgia Department of Transportation (GDOT)

Tennessee Department of Transportation (TDOT)

February 2017

PTSCO - 0023-00-002

PI: No. T001684
Tier 1 DEIS Public and Agency Involvement Summary Report

Atlanta-Chattanooga HSGT Tier 1 DEIS ii February 2017

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Tier 1 DEIS Public and Agency Involvement Summary Report

Atlanta-Chattanooga HSGT Tier 1 DEIS iii February 2017

Table of Contents

1.0 PUBLIC AND AGENCY INVOLVEMENT SUMMARY......................................................................1

1.1 INTRODUCTION...........................................................................................................1

1.1.1 Distribution of the Tier 1 DEIS.......................................................................1

1.1.2 Public Meetings .............................................................................................4

1.1.3 Additional Public Outreach Activities.............................................................5

2.0 COMMENTS AND RESPONSES........................................................................................................6

2.1 SUMMARY OF COMMENTS .......................................................................................6

2.2 SUMMARY OF REPONSES ........................................................................................6

3.0 TIER 1 FEIS AND ROD ........................................................................................................................7

3.1 COMBINED TIER 1 FEIS AND ROD ...........................................................................7

3.2 TIER 1 FEIS/ROD PUBLIC AND AGENCY INVOLVEMENT .....................................7

ATTACHMENT 1: LIST OF AGENCY CONTACTS AND INFORMATION DISTRIBUTED.......................8

ATTACHMENT 2: PUBLIC MEETING INFORMATION ..............................................................................44

ATTACHMENT 3: COMMENT AND RESPONSE MATRIX........................................................................77

ATTACHMENT 4: CORRESPONDENCE RECEIVED DURING TIER 1 DEIS REVIEW PERIOD........124

List of Tables

Table 1: Libraries Displaying the Tier 1 DEIS During the Public and Agency Review Period .............3

Table 2: Placement of Legal Notices....................................................................................................4

Table 3: DEIS Public Meetings .............................................................................................................5

Table 4: Tier 1 DEIS Comments and Responses ..............................................................................78

List of Figures

Figure 1: Federal Register Notice of Availability for Atlanta to Chattanooga HSGT Tier 1 DEIS........2

Figure 2: Public Meeting Board #1 .....................................................................................................46

Figure 3: Public Meeting Board #2 .....................................................................................................47

Figure 4: Public Meeting Board #3 .....................................................................................................48

Figure 5: Public Meeting Board #4 .....................................................................................................49

Figure 6: Public Meeting Board #5 .....................................................................................................50
Tier 1 DEIS Public and Agency Involvement Summary Report

Atlanta-Chattanooga HSGT Tier 1 DEIS iv February 2017

List of Acronyms

CBMPO Cartersville-Bartow Metropolitan Planning Organization

CEQ White House Council on Environmental Quality

DEIS Draft Environmental Impact Statement

DOI United States Department of the Interior

FAST Act Fixing America’s Surface Transportation Act

FEIS Final Environmental Impact Statement

FRA Federal Railroad Administration

GADNR Georgia Department of Natural Resources

GDOT Georgia Department of Transportation

HSGT High Speed Ground Transportation

LRTP Long Range Transportation Plan

MAP-21 Moving Ahead for Progress in the 21st Century Act

MPO Metropolitan Planning Organization

NEPA National Environmental Policy Act

NOA Notice of Availability 

ROD Record of Decision

TCC Technical Coordinating Committee

TDOT Tennessee Department of Transportation

USDA United States Department of Agriculture 

USDOT United States Department of Transportation

USEPA United States Environmental Protection Agency
Tier 1 DEIS Public and Agency Involvement Summary Report

Atlanta-Chattanooga HSGT Tier 1 DEIS 1 February 2017

1.0 PUBLIC AND AGENCY INVOLVEMENT SUMMARY

1.1 Introduction

Since the inception of the Atlanta to Chattanooga High Speed Ground Transportation (HSGT) Project

(hereinafter referred to as the Project), the Federal Railroad Administration (FRA), Georgia Department of 

Transportation (GDOT), and Tennessee Department of Transportation (TDOT) have been committed to a 

transparent public and agency involvement process for sharing information related to the Project and for

involving the public and other stakeholders in the decision-making process for the Tier 1 Draft 

Environmental Impact Statement (DEIS). Opportunities for public and agency involvement were provided 

at several key points throughout the environmental review process, and are detailed in Chapter 7.0 of the 

Atlanta – Chattanooga High Speed Ground Transportation Tier 1 DEIS.

This report describes the public and agency involvement process for the distribution of the Tier 1 DEIS, 

public and agency review period, public meetings, and other outreach activities following the publication of 

the Tier 1 DEIS in October 2016.

1.1.1 Distribution of the Tier 1 DEIS

The FRA signed the Atlanta – Chattanooga High Speed Ground Transportation Tier 1 DEIS in September 

2016. Following FRA’s approval of the Tier 1 DEIS, the FRA submitted copies of the Tier 1 DEIS 

document to the U.S. Environmental Protection Agency (USEPA), where it was recorded as EIS No. 

20160226. USEPA then published a Notice of Availability (NOA) in the Federal Register (Volume 81, No. 

195, page 69813) on October 7, 2016, providing notification that the Tier 1 DEIS was available for review 

and comment, officially opening the public and agency review period for the Tier 1 DEIS (Figure 1). FRA 

initially requested all comments be submitted by November 22, 2016, establishing a 45-day review period; 

however, this date was later extended to December 31, 2016 in response to requests for additional 

information and outreach activities by some agencies and jurisdictions.

The complete Tier 1 DEIS, including appendices, and the Tier 1 DEIS Executive Summary were made 

available for public review online via GDOT’s project website, accessible at

www.dot.ga.gov/IS/Rail/AtlantatoChattanooga and FRA’s project website accessible at

https://www.fra.dot.gov/Page/P0451. Digital copies of the Tier 1 DEIS were also made available at main 

branch libraries in each county within the project study area. Table 1 provides a list of these libraries

where the Tier 1 DEIS could be reviewed. Instructions for sending comments to FRA, GDOT, or TDOT

were included in the Tier 1 DEIS. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 2 February 2017

Figure 1: Federal Register Notice of Availability for Atlanta to Chattanooga HSGT Tier 1 DEIS
Tier 1 DEIS Public and Agency Involvement Summary Report

Atlanta-Chattanooga HSGT Tier 1 DEIS 3 February 2017

Table 1: Libraries Displaying the Tier 1 DEIS During the Public and Agency Review Period

State City County Libraries

GA

Atlanta Fulton Central Library (Atlanta-Fulton PLS)

Calhoun Gordon Calhoun-Gordon County Library

Canton Cherokee RT Jones Memorial Library

Cartersville Bartow Cartersville Main Street Library

Chatsworth Murray Chatsworth-Murray County Library

Dallas Paulding Dallas Public Library

Dalton Whitfield Dalton-Whitfield County Public Library

Douglasville Douglas Douglas County Public Library

Jonesboro Clayton Clayton County Headquarters Library

LaFayette Walker LaFayette-Walker County Public Library

Marietta Cobb Central Library, Cobb Co. PLS

Ringgold Catoosa Catoosa County Library at Benton Place Campus

Rockmart Polk Rockmart Library

Rome Floyd Rome/Floyd County Library

Summerville Chattooga Chattooga County Library

TN Chattanooga Hamilton Chattanooga-Hamilton County Bicentennial Library

Source: AECOM 2016

FRA and GDOT mailed letters notifying Native American Tribes, participating agencies, Federal and State 

agencies, and State and U.S. elected officials of availability of the Tier 1 DEIS and upcoming public 

meetings. The following materials were included in the mailing:

 A copy of the Tier 1 DEIS Executive Summary;

 Fall 2016 Project Newsletter; and

 Flash drives containing electronic copies of the Tier 1 DEIS Executive Summary, and Tier 1 DEIS, 

including appendices. 

FRA and GDOT relayed an email notification to local government offices, local elected officials, and all 

staff-level contacts within State and local-level agency offices, with a link to the GDOT project website

where the notice of public meetings, the Tier 1 DEIS Executive Summary, Tier 1 DEIS and appendices, 

and HSGT Project Newsletter could be reviewed. Legal notices announcing public meetings and the 

availability of the Tier 1 DEIS appeared in 17 newspapers designated as legal organs for each county

listed in Table 2. The legal notices were placed in each newspaper during the last week of October 2016 

and ran through the third week of November 2016. Attachment 1 contains a list of contacts from each 

Native American Tribe, Federal, State, and local agency, and a copy of all information distributed during 

the public and agency review period.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 4 February 2017

Table 2: Placement of Legal Notices

State Newspaper County of Legal Organ Date Published

GA

Calhoun Times Gordon County October 2016

Clayton News Daily Clayton County October 2016

Douglas County Sentinel Douglas County October 2016

Fulton County Daily Report Fulton County October 2016

Marietta Daily Journal Cobb County October 2016

Rome News-Tribune Floyd County October 2016

The Catoosa County News Catoosa County October 2016

The Cedartown Standard Polk County October 2016

The Chatsworth Times Murray County October 2016

The Cherokee Tribune Cherokee County October 2016

The Daily Citizen News Whitfield County October 2016

The Daily Tribune News Bartow County October 2016

The Dallas New Era Paulding County October 2016

The Summerville News Chattooga County October 2016

Walker County Messenger Walker County October 2016

TN

Chattanooga Times Free Press Hamilton County October 2016

Hamilton County Herald Hamilton County October 2016

Source: AECOM 2016

1.1.2 Public Meetings

During the public and agency review period, the FRA and GDOT held three public meetings in Atlanta, 

GA, Chattanooga, TN, and Dalton, GA. The purpose of the public meetings was to provide agencies and

the public with the opportunity to learn about the proposed project, ask questions, and solicit public 

comment on the DEIS, the proposed alternatives, and other issues related to the development of the 

Project. Those with an interest in the Project who were not able to attend the meetings were able to 

participate by reviewing information shared on the GDOT project website. Additionally, those who viewed 

the website were able to offer comments on the project through the project email address or by sending

written comments to the GDOT Project Address or to the FRA.

Notice of public meetings and the availability of the Tier 1 DEIS and other project information were

advertised for approximately two weeks prior to the date of each public meeting through advertisements in 

the newspaper legal organs for each county (Table 2) within the project corridor and through GDOT-run 

social media, the Fall 2016 Project Newsletter, and email notifications. Table 3 provides a list of public 

meeting locations and attendance. Attendance numbers reported here are based on the number of 

persons who registered on a sign-in sheet and may slightly underestimate the actual number of attendees

since it was not mandatory for attendees to provide their information on the sign-in sheet. Based on signin sheet information, 93 persons attended the three public meetings. 
Tier 1 DEIS Public and Agency Involvement Summary Report

Atlanta-Chattanooga HSGT Tier 1 DEIS 5 February 2017

Table 3: DEIS Public Meetings

Public 

Meeting Location Date/Time Number of attendees1

Atlanta, GA

GDOT General Office

One Georgia Center

Room 403 and 404

600 West Peachtree Street, NW

Atlanta, GA 30308

Tuesday,

November 15, 2016

6:00 PM to 8:00 PM

16

Chattanooga, 

TN

Chattanooga-Hamilton County Regional Planning 

Agency (CHCRPA)

Development Resource Center

Conference Room 1A-50

1250 Market Street # 2000

Chattanooga, TN 37402

Wednesday, 

November 16, 2016

6:00 PM to 8:00 PM

25

Dalton, GA

City of Dalton City Hall and Administration Building

Main Auditorium

300 W. Waugh Street

Dalton, GA 30720

Thursday,

November 17, 2017

6:00 PM to 8:00 PM

52

Total 93

1

Based on the number of individuals who registered on the sign-in sheets. Additional persons may have been present but did 

not choose to register.

Source: AECOM, 2016

Meeting attendees received handouts including the Fall 2016 Project Newsletter, facts, and frequently 

asked questions. Meeting attendees also had the opportunity to review project information on a series of 

five project boards and a looping PowerPoint presentation with voiceover narration. Information handed 

out during the public meetings and a copy of the presentation slides are included in Attachment 2. 

Comment cards were available to submit written comments and a separate area was set up for those who 

wished to make private comments to a court reporter.

Due to audio-visual problems during the looping presentation, the format for the public meeting in Dalton, 

Georgia was changed to accommodate the number of attendees present. The PowerPoint for the looping 

presentation was shown and a speaker verbally narrated each slide. Afterwards, attendees were allowed 

to ask questions and representatives from FRA and GDOT were available to provide responses. 

1.1.3 Additional Public Outreach Activities

Following the three public meetings, representatives from the City of Cartersville and Bartow County 

requested an additional briefing to their constituents due to the proximity of all evaluated 

alternatives. In response to this request, FRA, GDOT, and Cartersville-Bartow Metropolitan 

Planning Organization (CBMPO) agreed that GDOT would attend one of the regularly scheduled

CBMPO Technical Coordinating Committee (TCC) meetings to share information on the project and 

its potential impacts to the City of Cartersville and Bartow County. GDOT representatives provided a 

brief presentation to the CBMPO TCC during the regularly scheduled TCC meeting on January 18,

2017. CBMPO TCC meeting attendees were invited to provide comments on the DEIS through 

January 31, 2017. The meeting announcement, invitation to provide comments, and information 

provided by GDOT at the TCC meeting was available on the CBMPO website.
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Atlanta-Chattanooga HSGT Tier 1 DEIS 6 February 2017

2.0 COMMENTS AND RESPONSES

The FRA, GDOT, and TDOT encouraged public review and comment on the Tier 1 DEIS at each of the 

public meetings and through notices, the Fall 2016 Project Newsletter, and other publications and made it 

known that responses to comments would be published in the Tier 1 Final Environmental Impact 

Statement (FEIS). The following provides a summary of the comments received and responses for the 

Tier 1 DEIS. A comment and response summary table is included in Attachment 3.

2.1 Summary of Comments

During the review period for the Tier 1 DEIS, the FRA, GDOT, and TDOT received a total of 49

correspondence items. Each letter, email, comment card, court reporter transcript and telephone 

comment transcription received are included in Attachment 4. The comments in each 

correspondence item represent viewpoints from Native American Tribes, Federal, State and local 

government agencies, businesses, residents, interested individuals, and property owners. 

Of the submittals, 28 comments generally were in support of the HSGT Project, and two (2) were 

generally opposed to the HSGT Project. The remaining comments were on specific information 

provided in the Tier 1 DEIS, requesting further review information, or acknowledging receipt and 

review of the Tier 1 DEIS. Most comments were received from the public, either through written or 

oral comments at public meetings or were submitted after the public meetings during the Tier 1 DEIS 

public and agency review period. Most comments indicating support for a particular Corridor

Alternative evaluated in the Tier 1 DEIS supported the I-75 Corridor Alternative, due to the minimal 

environmental impacts associated with the existing transportation corridors that comprise the I-75 

Corridor Alternative and a more direct route between Atlanta, GA and Chattanooga, TN. A few 

public comments also suggested that a hybrid corridor alternative of the I-75 and I-75/Rome Corridor

should be considered, citing the importance of serving Rome as a key factor. However, these 

options were already evaluated and rejected from further consideration during the corridor screening 

process due to poor performance under the Project’s screening criteria and the failure to effectively 

meet the Purpose and Need for the Project (see Tier 1 DEIS Chapter 1.0 and Chapter 2.0). 

2.2 Summary of Reponses

GDOT has reviewed all of the comments and prepared responses. Comments generally fell into the 

following broad categories:

 Generally supportive of the project;

 Supportive of the project based on a specific Corridor Alternative;

 Generally opposed to the project;

 Detailed and substantive comments concerning information provided in the DEIS; and

 Requesting further information on the Project.

FRA, GDOT, and TDOT have taken public and agency comments into consideration in the decisionmaking process for the Tier 1 EIS. A brief description of the response to the comments based on 

information included in the Tier 1 DEIS and Tier 1 DEIS errata sheets is included in Attachment 3. 

When FRA issues the Tier 1 FEIS/ROD, letters will be sent to all individuals and agencies that 

provided comments during the public and agency review period. The letters will inform the 

commenters that the Tier 1 FEIS/ROD, which includes responses to comments, is available for 

inspection for approximately 30 days after the FRA official signs the Tier 1 FEIS/ROD document. 
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Atlanta-Chattanooga HSGT Tier 1 DEIS 7 February 2017

3.0 TIER 1 FEIS AND ROD

3.1 Combined Tier 1 FEIS and ROD

Transportation law entitled Moving Ahead for Progress in the 21st Century Act (MAP-21) (Public Law 112-

114) and the Fixing America’s Surface Transportation (FAST) Act (Public Law 114-94) have streamlined 

the National Environmental Policy Act (NEPA) process for United States Department of Transportation 

(USDOT) projects. The law directs the USDOT, where possible, to issue a combined FEIS and Record of 

Decision (ROD). The FAST Act incorporates environmental streamlining requirements, including the use 

of errata sheets and developing a combined FEIS/ROD.

In compliance with these requirements, FRA is preparing a combined Tier 1 FEIS/ROD that utilizes errata 

sheets attached to the Tier 1 DEIS for this Project. The combined Tier 1 FEIS/ROD will be prepared 

pursuant to environmental laws, regulations, and executive orders applicable during the environmental 

review process for a Tier 1 EIS. The purpose of the Tier 1 FEIS/ROD is to respond to substantive 

comments received during the public and agency comment period. Responses will be in the form of 

factual corrections or clarifications. The use of errata sheets in lieu of rewriting the DEIS is appropriate 

when comments received on a DEIS are minor and the responses to those comments are limited to 

factual corrections or explanations of why the comments do not warrant further response. No comments 

warranted further response in the form of additional alternatives or consideration of undisclosed project 

impacts. The DEIS errata sheets will be included in the combined Tier 1 FEIS/ROD and will also be 

available with the Tier 1 DEIS on FRA’s and GDOT’s HSGT Project websites. The Tier 1 DEIS will be

included as an appendix to the combined Tier 1 FEIS/ROD.

The ROD portion of the Tier 1 FEIS/ROD will state the decision; identify the alternatives considered in 

reaching the decision; summarize avoidance, minimization, and mitigation strategies and future design 

practices appropriate for the Tier 1 EIS; and state the next steps in the environmental review process that 

may occur with subsequent phases of the HSGT Project. Members of the public, project stakeholders, 

local governments, elected officials, non-governmental organizations, and Native American Tribes, 

Federal, State, and local agencies have been and will continue to be involved in the Project throughout 

any subsequent phases. 

3.2 Tier 1 FEIS/ROD Public and Agency Involvement

The FRA will hold at least a 30-day waiting period after the release of the Tier 1 FEIS/ROD allowing 

the public, stakeholders, Native American Tribes, Federal, State, and local agencies the opportunity 

to review and provide input on the Preferred Corridor Alternative indentified in the Tier 1 FEIS/ROD 

and the contents of the Tier 1 FEIS/ROD. This will not be a formal review and comment period and 

the FRA, GDOT, and TDOT will not respond to individual comments as was required during the Tier 

1 DEIS. Rather, any correspondence received will become part of the the environmental review files 

for the Project and FRA, GDOT, and TDOT will consider input received on the Tier 1 FEIS/ROD for 

any subsequent phases of the Project, which may include a Tier 2 NEPA process. 
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 1

Atlanta-Chattanooga HSGT Tier 1 DEIS 8 February 2017

ATLANTA-CHATTANOOGA

HIGH SPEED GROUND TRANSPORTATION PROJECT

TIER 1 DEIS PUBLIC AND AGENCY 

INVOLVEMENT SUMMARY REPORT

ATTACHMENT 1: LIST OF AGENCY 

CONTACTS AND INFORMATION 

DISTRIBUTED

Prepared by:

Federal Railroad Administration (FRA)

Georgia Department of Transportation (GDOT)

Tennessee Department of Transportation (TDOT)

February 2017
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 1

Atlanta-Chattanooga HSGT Tier 1 DEIS 9 February 2017
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Attachment 1

Atlanta-Chattanooga HSGT Tier 1 DEIS 10 February 2017
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Attachment 1

Atlanta-Chattanooga HSGT Tier 1 DEIS 11 February 2017
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Atlanta-Chattanooga HSGT Tier 1 DEIS 12 February 2017
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Atlanta-Chattanooga HSGT Tier 1 DEIS 13 February 2017
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Atlanta-Chattanooga HSGT Tier 1 DEIS 14 February 2017
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Atlanta-Chattanooga HSGT Tier 1 DEIS 15 February 2017
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Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 44 February 2017

ATLANTA-CHATTANOOGA

HIGH SPEED GROUND TRANSPORTATION PROJECT

TIER 1 DEIS PUBLIC AND AGENCY 

INVOLVEMENT SUMMARY REPORT

ATTACHMENT 2: PUBLIC MEETING

INFORMATION

Prepared by:

Federal Railroad Administration (FRA)

Georgia Department of Transportation (GDOT)

Tennessee Department of Transportation (TDOT)

February 2017
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 45 February 2017
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Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 46 February 2017

Figure 2: Public Meeting Board #1
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 47 February 2017

Figure 3: Public Meeting Board #2
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

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Figure 4: Public Meeting Board #3
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 49 February 2017

Figure 5: Public Meeting Board #4
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 50 February 2017

Figure 6: Public Meeting Board #5
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 2

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Attachment 2

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Attachment 2

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Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 74 February 2017
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Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 75 February 2017
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Attachment 2

Atlanta-Chattanooga HSGT Tier 1 DEIS 76 February 2017
ATLANTA-CHATTANOOGA

HIGH SPEED GROUND TRANSPORTATION PROJECT

TIER 1 DEIS Public and Agency 

Involvement Summary Report

Attachment 3: Comment and 

Response Matrix

Prepared by:

Federal Railroad Administration (FRA)

Georgia Department of Transportation (GDOT)

Tennessee Department of Transportation (TDOT)

February 2017
Atlanta-Chattanooga HSGT Tier 1 DEIS 2 February 2017

Summary of Public and Agency Outreach

Table 4: Tier 1 DEIS Comments and Responses

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

1 Tom Sills, 

AICP

CartersvilleBartow MPO“I'm interested in knowing the reasons for the rail corridor. I 

suspect that it is a factor of the traffic expected along the I-75 auto 

corridor between Atlanta and Chattanooga, but there's nothing in 

this information that details what this rail corridor is expected to do 

in terms of its impact on that amount of traffic, and I'd be interested 

in seeing what that impact would be.”

The purpose of the HSGT Project, as stated in the DEIS is to enhance 

intercity mobility and economic growth throughout the HSGT Project Study 

Area between the metropolitan areas and the major airports in Atlanta, 

Georgia, and Chattanooga, Tennessee, by providing faster and more reliable 

ground transportation service to the public as an alternative to highway, 

intercity bus, and air travel in a manner that is safe and cost-effective, while 

avoiding, minimizing, and mitigating impacts on the human and natural 

environment. The purpose is supported by the Long Range Transportation 

Plans (LRTPs) of the Metropolitan Planning Organizations (MPOs) in the 

HSGT Project Area and the GDOT’s and TDOT’s State Implementation 

Plans. Traffic impacts and benefits will be evaluated during additional 

planning and environmental work in subsequent project phases. 

Court Reporter

2 Jonathan 

DiGioia

- “I think the major determining factor for how useful this system 

would be to me would be the fare cost for the user. Time of travel 

compared to driving on Interstate 75 would factor in as well, but the 

cost would be the most important thing to me.”

Fare structure would be determined in later phases of the study. Court Reporter

3 Richard 

Brock

Resident of 

Cartersville, GA

Richard Brock: “My name is Richard Brock. I'm a resident of 

Bartow County, the Cartersville area. I am on record as being in 

favor of the rapid rail. And also that I would be in favor of the 

Maglev technology as well, because of the fact that it is going to be 

the fastest. And, I think, in the long run, in terms of overall future, 

that it's something that would really be good to have, something 

that's going to be the fastest. If you wind up, get committed to 

something of a less, it would be much harder later on the redo -- to 

wind up upgrading the transportation system. Also, that I am in 

favor of the fastest way, particularly in terms of something that 

would probably be the most use, which would be the corridor 

straight through 75 as opposed to the East and West; however, I 

think it would be great if, maybe, particularly the West, it would link 

Rome, would be a good addition and to a future segment onto that, 

if it could be done. Also, I would like to make a comment in terms 

of the situation on the meeting, because I don't know how many 

people actually have been attending some of the meetings, but I 

only found out just by accident, because I was listening to the 

Atlanta media, and they mentioned that there was going to be a 

meeting Tuesday evening, the 15th. And I went on the Georgia 

DOT link to find out what -- more information about it and found out 

there was two other meetings, one in Chattanooga last night, and 

this one here in Dalton tonight. So, if it had been, I think more 

publicized, there's a good chance, I think, that maybe more people 

might be responding. I don't know if it's something of aware that a 

lot of it is going to be gauged by the amount of public input as to 

whether they think if its low turnout that maybe there may not be 

much interest. I think, certainly, there just may not be a lot of 

people informed about some of the meetings. So if that becomes 

as issue, I think it would be good to give more of a straw poll, or 

whatever, for the – “

Judy Brock: “Put it out in the local papers.”

General support for the project has been noted, with particular interest in the 

I-75 Corridor Alternative. Preference for Maglev technology is noted. Tier 2 

NEPA studies will define a high speed ground transportation technology.

Given the performance measures identified in the DEIS, the I-75 corridor is 

the best performing of the project purpose and need at the time. Further 

details, would be identified at further stages of the Project. While a spur line 

to Rome would not meet the Project’s current purpose and need, it could be 

a part of a separate but coordinated Project.

Noted comment about more widespread publication of meeting notices and 

advertisements. The Federal Register Notice was published on October 7, 

2016 and advertisements ran in the legal organs of each county within the 

Project Study Area from the last week in October 2016 to the third week of 

November 2016. 

Court Reporter DEIS Errata ID 5

(Section 2.1.1)
Atlanta-Chattanooga HSGT Tier 1 DEIS 3 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

Richard Brock: “Uh-huh (affirmative). And put it in -- get more 

media attention so that the would be the case. Certainly, I'm 

hoping that this will be something that will come to fruition. I know 

that I attended a meeting back in 2010 on this particular project, 

and it was killed. I hope this time, it will move forward.”

Judy Brock: “And I'm Judy Brock. And ditto for everything he said.”

4 Judy Brock Resident of 

Cartersville, GA

Richard Brock: “My name is Richard Brock. I'm a resident of 

Bartow County, the Cartersville area. I am on record as being in 

favor of the rapid rail. And also that I would be in favor of the 

Maglev technology as well, because of the fact that it is going to be 

the fastest. And, I think, in the long run, in terms of overall future, 

that it's something that would really be good to have, something 

that's going to be the fastest. If you wind up, get committed to 

something of a less, it would be much harder later on the redo -- to 

wind up upgrading the transportation system. Also, that I am in 

favor of the fastest way, particularly in terms of something that 

would probably be the most use, which would be the corridor 

straight through 75 as opposed to the East and West; however, I 

think it would be great if, maybe, particularly the West, it would link 

Rome, would be a good addition and to a future segment onto that, 

if it could be done. Also, I would like to make a comment in terms 

of the situation on the meeting, because I don't know how many 

people actually have been attending some of the meetings, but I 

only found out just by accident, because I was listening to the 

Atlanta media, and they mentioned that there was going to be a 

meeting Tuesday evening, the 15th. And I went on the Georgia 

DOT link to find out what -- more information about it and found out 

there was two other meetings, one in Chattanooga last night, and 

this one here in Dalton tonight. So, if it had been, I think more 

publicized, there's a good chance, I think, that maybe more people 

might be responding. I don't know if it's something of aware that a 

lot of it is going to be gauged by the amount of public input as to 

whether they think if its low turnout that maybe there may not be 

much interest. I think, certainly, there just may not be a lot of 

people informed about some of the meetings. So if that becomes 

as issue, I think it would be good to give more of a straw poll, or 

whatever, for the – “

Judy Brock: “Put it out in the local papers.”

Richard Brock: “Uh-huh (affirmative). And put it in -- get more 

General support for the project has been noted, with particular interest in the 

I-75 Corridor Alternative. 

Given the performance measures identified in the DEIS, the I-75 corridor is 

the best performing of the project purpose and need at the time. Further 

details, would be identified at further stages of the Project. While a spur line 

to Rome would not meet the Project’s current purpose and need, it could be 

a part of a separate but coordinated Project.

Noted comment about more widespread publication of meeting notices and 

advertisements. The Federal Register Notice was published on October 7, 

2016 and advertisements ran in the legal organs of each county within the 

Project Study Area from the last week in October 2016 to the third week of 

November 2016. 

Court Reporter DEIS Errata ID 5 

(Section 2.1.1)
Atlanta-Chattanooga HSGT Tier 1 DEIS 4 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

media attention so that the would be the case. Certainly, I'm 

hoping that this will be something that will come to fruition. I know 

that I attended a meeting back in 2010 on this particular project, 

and it was killed. I hope this time, it will move forward.”

Judy Brock: “And I'm Judy Brock. And ditto for everything he said.”

5 Laura 

Mumber

Rome, GA 

Business 

Owner

“I think a high speed rail way through Rome, GA would be a great 

idea. There are many times we would use the train to get to the 

Atlanta airport, instead of driving through Atlanta and paying to 

park our car. There are also many times we would use the train to 

attend our son's swim meet at Georgia Tech, instead of paying to 

park in the lot at the university. I have a vacation rental property 

where many guests fly in to stay with family members. The train 

would make it easier for our guests to arrive in Rome from the 

Atlanta airport, where they can be picked up by family members 

with their car. There are many who would travel into Atlanta or 

Chattanooga for the day more often if the train was available in 

Rome. Thank you for your consideration.”

Support for the project I-75/Rome Corridor Alternative has been noted. General Public 

Comment 1 –

11-4-2016

6 Mary 

Anglin

Resident of 

Chattanooga, 

TN

“I saw your legal notice in the Chattanooga Sun Times today on 

page F3 and I have applied for disability and I would like to 

comment on the notice, I will not be able to attend the meeting, but 

the notice was about rapid transportation to Cherokee County and 

I think that your Acworth shopping area, and I - would be very 

interested in that. So this is PI#TDD 1864 and I live in 

Chattanooga and this is an announcement for rapid transit in 

Georgia, but I'm interested in transportation to your shopping area 

in Acworth and I am disabled and qualified and I just wanted to call 

and let you know I won't be at the meeting, but that's the only 

comment I have. Thank you.”

General support for the project has been noted. General Public 

Comment 2 –

11-16-2016

7 Horace 

Benson 

Hatcher

Resident of 

Chattanooga, 

TN

“If high-speed rail is equivalent to the space race of the 1960s, 

America is badly behind, lacking the political will to do much. But

despite opposition from the auto, airline, and oil industries, private 

efforts to build high-speed rail are chugging ahead in California, 

Texas, Florida, Illinois, Nevada and other states. Fifty years from 

now, I want my grandchildren and all people in this country to look 

back at high-speed rail and think of it as being like the Dwight D. 

Eisenhower interstate system. Therefore, allow me to quote Davy 

Crocket, "Be always sure you're right, then go ahead." "We must 

rebuild yesterday for tomorrow." "Our future is high-speed rail 

today." Early studies from the World Bank and Morgan Stanley 

General support for the project has been noted. General Public 

Comment 3 –

11-16-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 5 February 2017

Summary of Public and Agency Outreach

Comment 

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Addressed in 

FEIS/ROD

indicate (that China's bet on high-speed rail makes financial sense. 

They place average annual operating cost of Chinese high-speed 

rail at $700 million per 621 miles, while commercial revenue brings 

in roughly $1 billion per 621 miles. Researchers say the rail 

system allows Chinese workers to be more productive as they 

commute to work. It reduces noise and air pollution and uses less 

fuel then cars, buses and airplanes, according to the U.S. 

Department of Transportation.”

8 Neil 

Brunetz

Miller & Martin, 

PLLC

“Having been to Europe and seen the use and efficiency of rail in 

action, I am very much in favor of seeing rail become more 

prominent in this country. The advent of high-speed rail would 

provide an alternative to automobile traffic between relatively close 

metropolitan areas such as Chattanooga and Atlanta. Obviously, 

this could then be expanded to Nashville and other metropolitan 

centers. Somewhere has to start the trend and I believe the ATLCHA route is one that would be used heavily. Intermediate stops 

in Dalton and other places would obviously contribute to the use of 

rail. I travel quite often to Atlanta and to have the option to ride, 

work and be productive while on the train is very appealing. The 

thought of avoiding 9am traffic into Atlanta from Chattanooga is 

also extremely appealing. Rail would also make spending a 

Saturday in Atlanta for sporting events or shopping a more likely 

possibility. I appreciate the group taking the time to study the 

proposal and look forward to helping those see it implemented. 

Thanks for looking towards the future.”

General support for the project has been noted. General Public 

Comment 4 –

10-31-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 6 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

9 Matthew 

Pociask

- “Good afternoon, I am glad to see that this necessary piece of 

infrastructure move forward - my first comment would be that this 

has been in the planning since 1998 at least, and it's about time we 

move from planning to building! My second comment, however, is 

to sharply dispute the plan to build an entirely new rail line from 

Atlanta to Chattanooga. The state of Georgia already owns a 

perfectly good rail line that goes along that exact route - the 

Western & Atlantic rail line. It is currently under lease to CSX, a 

lease which I understand expire in 2019. So let it expire! Build 

passenger stations, and do any necessary track upgrades to serve 

high speed passenger service instead of freight. If you're feeling 

charitable, offer to let CSX build another line along the existing 

route so they can continue utilizing that route, but the main thing is, 

why would we pay $8-$9 billion dollars to duplicate something that 

the state of Georgia already owns free and clear? My third 

comment is to question the extension of the route from the 

Cumberland area to the Atlanta airport. A cynic might suggest that 

this is a backdoor route to give Cobb county residents bullet train 

access to the airport, even after they've repeatedly and publicly 

refused to join MARTA. A skeptic might wonder why Cobb 

residents would be gifted this high speed access by state and 

federal funds, while residents of DeKalb and Fulton are left with the 

slow poke access to the airport they currently are limited by. In 

any event, the southern terminus of any rail line to Chattanooga 

should be downtown, and no further. There is existing rail access 

from downtown to the airport already - MARTA. Again, why are we 

duplicating pre-existing functionality at substantial cost? If 

residents of Cobb county want better access to the airport, let them 

pay for MARTA like everyone else. In the meantime, save the 

projected costs by getting rid of all that expensive downtown 

construction necessitated by going from downtown to the airport, 

and end the line at downtown. If Cobb would get on board with 

MARTA, and the existing MARTA trunk planned to go out to 

Cumberland would get built in an ideal world, I'd even say end the 

route there. You are going to need to link in to MARTA anyway - a 

intercity rail system that doesn't connect with the intracity rail 

system would be a folly of epic proportions. My fourth comment is 

on the route proposal. I understand the time savings by cutting out 

Rome, but Rome is a beautiful downtown area, full of colleges, 

hospitals, etc. It has already been snubbed once by the 

development of the interstate system. I would ask for it not to be 

snubbed again by cutting it off from the intercity rail system. And if 

we're being totally honest, why has a bigger draw for tourists -

scenic historic Rome, or Dalton, the city known for carpet 

factories? Dalton already has interstate access to Chattanooga 

and Atlanta. Rome has neither. If there's an equity in the planning 

process, correcting this problem should push the Rome route to 

the top. And if the increase in trip time is the big concern, have you 

considered cutting out Dalton? You could take a route along the 

pre-existing US-27 corridor straight from Rome to Chattanooga. 

Support for the project I-75/Rome Corridor Alternative has been noted. General Public 

Comment 5 –

10-31-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 7 February 2017

Summary of Public and Agency Outreach

Comment 

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Addressed in 

FEIS/ROD

Dalton would unfortunately be cut out - but then again, by the 

current plan, Rome is being cut out. If one has to be cut, I'd wager 

a public poll would reveal a clear preference for the Rome/Lookout 

Mountain route, as opposed to the Dalton/interstate-frontage route. 

Thank you for taking the time to consider my comments. Regards, 

Matthew Pociask, A.B. History, UGA, J.D., UGA Decatur, GA”

10 Sylvia G. - “It's obvious: Build the Green Line immediately with a spur to 

Rome. Bus to Dalton until there is enough ridership to support a 

spur of its own.”

Support for the project I-75 Corridor Alternative has been noted. General Public 

Comment 6 –

11-3-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 8 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

11 Brenda 

Roberts

- “I write to voice my concern regarding the plans to build a high 

speed rail system from Atlanta to Chattanooga. I think this is a 

complete waste of money. With the continuing growth of the 

Atlanta Region and I'm not calling Chattanooga part of that Atlanta 

Region, I would think that the "Georgia" Department of 

Transportation could come up with a better use for those 

funds. Transportation is the no.1 problem in and around Atlanta 

and I believe that is where the monies for transportation should be 

spent. We need to expand Marta. There is no other option if we 

are to stop spending all of our time in cars getting to and from work 

and GDOT needs to help with this problem. I realize Atlanta is not 

all of Georgia but at least it is in GA and not in Tennessee. More 

and more businesses are moving to Atlanta as are regular citizens 

from across this country and those who are right here in the 

Atlanta area who are tired to the long drives to work and are now 

moving back into the city. The current transportation model of 

everyone hopping in their cars and going everywhere has to 

change and that will only happen with a rail system that moves 

people quickly in and around the city. The idea of a N/S/E/W 

transit system is a joke. Marta needs to expand their lines in all of 

those directions but also off the grid and into other areas around 

the city. Building more roads and expanding bus transportation will 

not work. The only way people will ride buses is if they don't have 

a car because it takes too long. They will however, get on a train if 

it will get there where they want to be in a reasonable amount of 

time. GDOT should be working on that premise. How to get 

people out of cars and onto transit!!! Convenience is the name of 

the game and you folks are not dealing with the right issues in the 

right way and while you are thinking about high speed rail to 

Chattanooga, you should be thinking about how to move people 

from Gwinnett County to Downtown Atlanta without a car. How to 

get people from Conyers to Alpharetta without a car and other 

possibilities like that? Please don't spend taxpayer money on this 

folly. How many people do you expect to move from Atlanta to 

Chattanooga daily and where would you get the most boom for the 

buck? You talk about regional growth from Atlanta to Chattanooga 

and other cities and states but that will only bring more traffic 

problems and no viable solutions. Instead of getting people from 

Atlanta to Chattanooga, try to get people from one side of town to 

the other. Thanks, Brenda Roberts”

General opposition to the project has been noted. General Public 

Comment 7 –

11-7-2016

12 Dave 

Callaway

Callaway 

Advertising

Hello, I own some land south of Ringgold along the CSX path. Can 

you email me a more detailed map than the one on your website? 

Thank you. 

At the current stage of the project, only broad corridor alternatives have been 

evaluated; more detailed maps will be provided at later stages of the project.

General Public 

Comment 8 –

11-7-2016

13 Robert 

Webb

- “Hello, I won't be able to attend the public discussion session in 

Dalton due to prior commitments, but I wanted to reinforce a key 

point that seems to be ignored. If someone in Chattanooga rides 

the train to Atlanta, he or she can link into the MARTA system, 

which isn't perfect, but can get people to key points. For a rider 

from Atlanta to Chattanooga, arriving is somewhat more 

problematic because CARTA service is limited and won't get most 

General support for the project has been noted. Coordination with local 

transit providers in the city locations where HSGT stations are proposed 

would occur in subsequent phases of the project. Transit service 

improvements would be evaluated by the transit providers and would be 

implemented as separate projects from the HSGT Project. Ancillary facilities 

such as park and ride lots and parking facilities at stations would be 

evaluated with subsequent phases of the HSGT project and this would 

General Public 

Comment 9 –

11-13-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 9 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

travelers to key tourist and business areas outside of downtown. 

Now, you have suggested that the train could have multiple stops 

between Chattanooga and Atlanta, potentially including Dalton, 

Calhoun, Cartersville and Marietta or Kennesaw. With the possible 

exception of Marietta, the only value of these stops would be for 

people to park locally and take the train to Atlanta. No one from 

Atlanta or Chattanooga would use the train to come to these 

communities, because they have no public 

transportation infrastructure to get people from the train to their 

eventual destinations. They're too small for Uber, and taxis would 

be prohibitively expensive for most day travelers. What's more, in 

Dalton, the average wait for a taxi is 15-20 minutes, so that adds 

another level of inconvenience. This leads me to two additional 

questions: Who will be responsible for building the parking lots 

needed for the travelers who will have to drive to these train stops 

on their way to Atlanta or Chattanooga? And who will make up for 

the lost revenues from local retail and restaurant traffic in those 

communities that is shifted to Atlanta or Chattanooga as they 

become easier options for day trips? (To say nothing of lost local 

option sales tax collections in those areas.) I'm not opposed to train 

travel. I use it in Europe often and comfortably, but the rail system 

there connects into city centers and makes it easy for people to 

reach their destinations. Small Georgia towns lack city centers or 

anything resembling urban planning. It will be a challenging 

proposition to make this work, but it will be good for Atlanta and 

Chattanooga. Thank you. Robert Webb.” 

include coordination with entities who would be responsible for construction 

and operation and maintenance of the facilities. Subsequent phases of 

planning for the HSGT project would include economic impacts analyses that 

would project the potential impacts—both positive and negative—for the 

communities within the selected HSGT Project corridor. 

14 Barry 

Atwood

Resident of 

Atlanta, GA

“I fully support building this project with the most direct route in 

coordination with other commuter rail services that the state should 

be providing in Atlanta as a transport hub.”

General support for the project has been noted. General Public 

Comment 10 –

11-23-2016

15 Virginia 

Merdes

Resident of 

Rome, GA

“Dear Ms. Ariel Heckler, Please do carefully consider the Rome, 

GA route of the high speed rail project. It is so difficult to drive to 

either. The Atlanta or Chattanooga airports shuttles are limited 

and expensive. Thanks for your work on this project and your 

consideration.”

Support for a corridor alternative through Rome has been noted. General Public 

Comment 11 –

11-22-2016

16 Tom Heard - “INSTEAD OF RE-INVENTING THE WHEEL, CAN WE NOT 

WORK WITH THE EXISTING RAIL SYSTEM? A HIGH SPEED 

PEOPLE HAULER AND NO CARGO IS GOING TO BE A TAX 

PAYER NIGHTMARE. THIS SYSTEM YOU ARE PROPOSING 

IS NOT SUSTAINABLE AND TRUMPED UP FEASIBILITY 

STUDIES ARE THE NORM. IF DONALD TRUMP GETS 

BEHIND THIS DEAL,THEN THIS COUNTRY IS IN FOR A BAD 

RIDE. THIS PROJECT IS A BAG OF WORMS AND 

HOPEFULLY WILL GO DOWN IN HISTORY AS NOTHING BUT 

A WASTE OF TIME AND MONEY. TOM 

HEARD/tom21171@yahoo.com”

General opposition to the project has been noted. General Public 

Comment 12 –

12-2-2016

17 Faith

Everett

Rocky Face 

Estates

“While I can see the value of having such a mode of transportation 

I am experiencing a bit of "nimby" reaction. As a resident of and 

representative for the Rocky Face Estates subdivision off Tibbs 

Road I would nice to voice a concern that this project will 

negatively affect our property values. This quiet, peaceful, lovely 

Mixed support for the project has been noted.

Further details, including mitigation and minimization efforts for any impacts 

will be identified at further stages of the HSGT Project, and impacts to 

neighboring communities will be minimized to the extent possible.

General Public 

Comment 13 –

11-30-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 10 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

neighborhood was established in the 1970s and is now enjoying 

being rejuvenated by many residents. As property owners, 

remodeling is an expensive venture and we are not interested in 

seeing our investments in updating our homes result in a loss of 

value.”

18 Charles 

Paine

Resident of 

Atlanta, GA

“Ms. Heckler, 

I am an Atlantan that is temporarily located in Charleston for 

School. 

I wanted to reach out today regarding the potential for High Speed 

Rail connecting Atlanta to Chattanooga. After looking at the 

proposed routes I would like to make a suggestion that you may 

like, or dislike. I think is important to understand that rail stations 

must be located in locations that avoid the use of automobiles to 

arrive at, and there is a large population of Atlanta’s working class 

that lives along the interstate, but also Rome. With financials in 

mind I would like to suggest a hybrid route of the direct I-75 route, 

with an extension branch to Rome, GA, rather than one single line. 

Similar to how MARTA has utilized the partially shared routes of its 

gold/red lines. This would allow Rome to also become a suburb of 

Atlanta, especially if the station is located in a pedestrian friendly/ 

central location in Rome. This would mean less rail is needed for 

the routes construction and it also would maximize the use of the 

system. The green line, straight up I-75, is unpleasant as a train 

route and will be difficult to access unless you live in Atlanta or 

Chattanooga. Allowing Rome to have a branch connected will 

increase ridership all together. Just keep in mind, quality and 

location of the routes, including the aesthetic, will make people 

more eager to become a part of the rail-movement. 

Thanks for your help with this. I'm sorry I could not attend any 

meetings, but I have been left out of the loop. Also I have begun a 

cause to Rebuild Atlanta’s Grand Train Stations, and If you have 

any questions, I am eager to become a part of the revitalization of 

Rail-Transit in Georgia. 

Thanks, 

Charles Paine”

General support for the project has been noted. 

Given the performance measures identified in the DEIS, the I-75 corridor is 

the best performing of the HSGT Project’s purpose and need. Further 

details, would be identified at further stages of the Project. While a spur line 

to Rome would not meet the Project’s current purpose and need, it could be 

a part of a separate but coordinated project.

General Public 

Comment 14 –

1-21-2017

19 Robert 

Krone

GA Chapter 

Sierra Club & 

Citizens for 

Progressive 

Transit

“High speed rail needs to be developed in Georgia. Infrastructure 

is a current topic with the election accomplished and passenger rail 

projects need to be at the head of the list.”

General support for the project has been noted. Public Hearing Written 

Comments November 

2016

20 Jonathan 

Gibbons

RPA “My only concern is the construction of station in areas that lack 

density of population or specific areas of interest, such as the 

airport. The fewer the stations, the better.”

Specific locations for stations and ancillary facilities would be evaluated 

during subsequent phases of the HSGT Project. The cities identified within 

each corridor are potential cities where stations could be located and are 

identified for further evaluation with subsequent phases of the HSGT Project. 

Public Hearing Written 

Comments November 

2016

21 Ron 

Wittlefield, 

FAICP

Former Mayor 

of Chattanooga

“This proposed project addresses two major problems with no 

simple or inexpensive solution: 1) The over-capacity I-75 with 

diminishing returns from additional widening and 2) Traffic 

originating north of Atlanta that must pass through or around 

Atlanta to access HJAIA (Thereby exacerbating the city's traffic 

gridlock). The cost of adding runways to HJAIA makes the direct 

General comment noted. The purpose of the HSGT Project, as stated in the 

DEIS is to enhance intercity mobility and economic growth throughout the 

HSGT Project Study Area between the metropolitan areas and the major 

airports in Atlanta, Georgia, and Chattanooga, Tennessee, by providing 

faster and more reliable ground transportation service to the public as an 

alternative to highway, intercity bus, and air travel in a manner that is safe 

Public Hearing Written 

Comments November 

2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 11 February 2017

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Comment 

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Section/Table 

Addressed in 

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connect to another well positioned airport a more sensible solution 

that, in spite of its cost, offers multiple benefits to all impacted 

communities.” 

and cost-effective, while avoiding, minimizing, and mitigating impacts on the 

human and natural environment. The purpose is supported by the Long 

Range Transportation Plans (LRTPs) of the Metropolitan Planning 

Organizations (MPOs) in the HSGT Project Area and the GDOT’s and 

TDOT’s State Implementation Plans.

22 Dr. Shawn 

Trivette

UTC-Dept. of 

Social, Cultural, 

& Justice 

Studies

“I strongly support the development of this HSGT corridor. Not 

only would it be an economic development opportunity & a 

regional resiliency investment (as noted in the EIS presentation) it 

is an important step in environmental management in light of 

decreasing oil resources & the growing threat of climate change. 

Especially considering Chattanooga's rail history it is high time we 

had high speed rail access here. I am curious how close this route 

will go the ATL Amtrak station or if a connector would be possible 

should the routes not overlap, that would further build 

transportation capacity.”

General support for the project has been noted. Coordination with providers 

of other modes of transportation and potential connections will be evaluated 

in subsequent phases of the HSGT Project. 

Public Hearing Written 

Comments November 

2016

23 W. Scott 

Anderson

Citizen/Busines

s Owner

“The Atlanta/Chattanooga high speed rail system cannot happen 

soon enough. In 1986 when I moved to Marietta, the freeway was 

2 lanes each direction. I think they are up to over 8 lanes now. I 

do not want an 8+ lane freeway all the way between ATL & CHA 

on through our city. The nation needs passenger rail connectivity 

nationwide. We cannot start soon enough. The U.S.A. is behind 

on this initiative. There is no better infrastructure and jobs project 

for this country.”

General support for the project has been noted. Public Hearing Written 

Comments November 

2016

24 Rob 

Bradham

- “The I-75 corridor option is the most efficient and cost sensitive 

option and should therefore be the preferred option.”

Support for the project I-75 Corridor Alternative has been noted. Public Hearing Written 

Comments November 

2016

25 Deanna 

Mathis

- “Love the proposed, hope tier 2 is funded!” General support for the project has been noted. Public Hearing Written 

Comments November 

2016

26 Gretchen 

Lugthart

- “The 75 Corridor option is the one that I support. Looks like it has 

the least environmental impact. It also has a stop in Dalton, where I 

work and very near where I reside (Rocky Face).”

Support for the project I-75 Corridor Alternative has been noted. Public Hearing Written 

Comments November 

2016

27 Steve 

Morrows

DVD Capital 

Partners

“This train would be the best facilitation of growth in this region.” General support for the project has been noted. Public Hearing Written 

Comments November 

2016

28 James 

Tucker

Citizen/local 

attorney

“*GO DOWN THE MIDDLE OF I-75 ON PYLONS* 

-Don't go near the wilderness area

-don't go to Rome, off the beaten trade too far

-make sure if goes 180 mph (Don't go slow; not worth it)

-maglev if possible please!!”

Support for the project I-75 Corridor Alternative with preference to Maglev 

technology has been noted. Tier 2 NEPA studies will define a high speed 

ground transportation technology. Additionally, impacts to areas such as 

parks and wildlife areas will be further evaluated in subsequent phases of the 

HSGT Project. 

Public Hearing Written 

Comments November 

2016

DEIS Errata ID 5 

(Section 2.1.1)

29 Virgelia C. 

Meek

League of 

Women Voters 

of Dalton

“As a frequent traveler I am very much in favor of the I-75 corridor.

If available I would travel several times a year. Many of my friends 

who are 65 and over would ride the train to connect to airports. My 

preference would be to have a Tennessee terminus at Lovell Field. 

Some questions were answered!”

Support for the project I-75 Corridor Alternative has been noted. Station 

locations will be further evaluated in subsequent phases of the HSGT 

Project. 

Public Hearing Written 

Comments November 

2016

30 Peter 

Pociask

- “This is a clear win for the city and state build this now!” General support for the project has been noted. Public Hearing Written 

Comments November 

2016

31 Mary Lynn 

Benton

- “East route too extended not populous enough - conflict w/Part in 

Murray County? Only 2 stops at 180 - 2 stops are enough! Don't 

General support for the project, with exception to the East Corridor 

Alternative has been noted. Preference to Maglev technology has been 

Public Hearing Written 

Comments November 

DEIS Errata ID 5 

(Section 2.1.1)
Atlanta-Chattanooga HSGT Tier 1 DEIS 12 February 2017

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slow it down. Steel on steel too much noise if we're going to go 

modern all the way w/mag-lev. Other countries make it work! 

Jobs-jobs-jobs!”

noted. 2016

32 Matthew 

Jackson

- “Emphasize job growth and economic growth more - more likely to 

get funding. Strongly in favor.”

General support for the project has been noted. Public Hearing Written 

Comments November 

2016

33 Lindsey 

Carson

Coldwell 

Banker Kinard 

Realty

“As a Gordon Co. resident, I do not feel a stop in Calhoun/Gordon 

Co. will be necessary since Dalton and Adairsville are so 

accessible for potential passengers.”

General support for the project has been noted. Station locations will be 

further evaluated in subsequent phases of the HSGT Project. 

Public Hearing Written 

Comments November 

2016

34 Mark 

Buckner

Chief Business 

Development 

Officer, Dalton 

Utilities

“Dear Ariel, I am writing to express Dalton Utilities' support of the 

proposed Atlanta to Chattanooga High Speed Ground 

Transportation Project. We understand that the project is in the 

planning process; however, we believe construction of this project 

would be a huge asset to our local community and to the states of 

Georgia and Tennessee. A quick look at commuting distances to 

the greater Dalton area for our current workforce shows that we 

draw employees from well north of Chattanooga and as far south 

as the northern Atlanta suburbs. A skilled and educated workforce 

is critical to our future success and to our ability to expand the 

strong manufacturing base we are so blessed to have. This 

transportation project would allow an avenue for a highly skilled 

workforce to travel to our community for employment as well as 

affording our citizens the opportunity to easily travel to 

Chattanooga and Atlanta for work or entertainment. Since you are 

in the feasibility and planning phase of this important project, we 

would like to highlight Dalton as a possible location for a 

maintenance facility for the rail engines and associated mechanical 

equipment that support such a project. We feel that our existing 

industry and those trades that support the industry base in Dalton 

would be an asset to such a maintenance facility. Also, we would 

like to pitch the idea of marrying a large diameter water 

transmission line along the proposed rail route in order to take 

advantage of right-of-way acquisition so that these projects could 

potentially partner in the right-of-way cost(s). Bulk transmission of 

drinking water from the northwest area of the State where 

resources are plentiful has the potential to support metro Atlanta's 

growth. It goes without saying that the potential positive economic 

impact of this project would be huge for our community and as 

such, we stand in full support of this project. We look forward to 

participation in the planning process and will support this project as 

it transitions from concept into reality. If we can be of further 

assistance as the project progresses, please don't hesitate to call 

me at (706) 529-1011 or e-mail at mbuckner@dutil.com. Sincerely, 

Mark Buckner”

General support for the project has been noted.

The location of a vehicle maintenance facility and detailed engineering of a 

rail alignment would occur during subsequent phases of the HSGT Project. 

Further coordination with utility providers, including evaluation of potential 

impacts—both positive and negative—will also occur during subsequent 

phases of the HSGT Project. 

Business-Dalton 

Utilities - Comments 11-

9-2016

35 Melissa 

Taylor

ChattanoogaHamilton 

County 

Regional 

Planning 

Agency & 

“Dear Commissioner: The Chattanooga-Hamilton County/North 

Georgia Transportation Planning Organization's active 2040 

Regional Transportation Plan calls attention to the Atlanta to 

Chattanooga High Speed Rail project addressing the following 

milestone accomplishments and status: 

A Tier I Environmental Assessment (EA) has been completed;

General support for the project has been noted, with particular interest in the 

I-75 Corridor Alternative. Further coordination with the TPO and other TPOs 

and MPOs within the selected corridor will occur during subsequent phases 

of the HSGT Project. The current phase of the project includes the 

preparation of a Tier 1 Environmental Impact Statement (EIS) for the 

selection of a corridor from Atlanta, GA to Chattanooga, TN where additional 

Chattanooga-Hamilton 

County North Georgia 

TPO Comments 11-9-

2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 13 February 2017

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ChattanoogaHamilton 

County/North 

Georgia 

Transportation 

Planning 

Organization

A Tier II Environmental Impact Statement (EIS) for this segment is 

currently underway by Georgia; and 

High Priority Project funds were also obligated in the CHCNGA's 

TPO's FY 2011-2014 TIP for a feasibility study of the Chattanooga 

to Nashville segment.

The 2040 plan further supports this project by suggesting the 

project would expand opportunity for existing and future 

connections to converge at the Chattanooga Metropolitan Airport, 

adding to the pressure to provide better transit service and 

providing opportunity to make this a mobility hub. However, the 

plan notes: "Federal funding has been appropriated, though not yet 

authorized, for the continuation of project development for the 

Atlanta-Chattanooga-Nashville high speed rail corridor. It is 

anticipated that these funds will be released in the near future. 

Funding for implementation of the project is expected to come from 

various sources including, but not limited to Federal Rail 

Administration, Federal Highway Administration, and Federal 

Transit Administration as well as state and local partners. Funding 

for this project will be included in a future RTP update given the 

status of the appropriations and likelihood the project will move 

forward in the future." Staff of the TPO continues to provide 

support and assist in planning functions association with seeing 

this project develop and supports the I-75 alignment for its reduced 

environmental impacts and high performance in the cost/benefit 

analysis. TPO staff also plans to attend the upcoming public 

meeting and looks forward to considering the project in the TPO's 

upcoming 2045 RTP expected for completion in 2018. Sincerely, 

Melissa D. Taylor.”

studies and analysis may identify potential alignments for future high speed 

rail or passenger rail service. 

36 Mayor 

Andy Berke

City of 

Chattanooga

“Thank you for the opportunity to comment on the Tier 1 Draft 

Environmental Impact Statement (DEIS) for the AtlantaChattanooga High Speed Ground Transportation (HSGT) Project. 

As a participating municipality for the project, the City of 

Chattanooga has a vested interest in seeing this project move 

forward. The City requests when the Federal Railroad 

Administration in cooperation with the Georgia Department of 

Transportation and Tennessee Department of Transportation 

move into the Tier 2 EIS for this great project that The 

Chattanooga Department of Transportation, CDOT be included in 

the local transportation agencies group. The City of Chattanooga 

fully supports the purpose of this project: to enhance intercity 

mobility and economic growth between Atlanta, Georgia and 

Chattanooga, Tennessee by providing faster and more reliable 

ground transportation as an alternative to vehicular or air travel. 

The City looks forward to continuing participation as this project 

moves through project development and becomes a reality for 

residents and tourists. The City of Chattanooga, through CDOT, 

has partnered with the Federal Railroad Administration and 

Tennessee Department of Transportation to begin evaluating the 

possibility to bring passenger rail back to Chattanooga, TN. The 

future Atlanta-Chattanooga ground transportation could be a great 

General support for the project has been noted.

Further coordination with local, state, and federal agencies would occur 

during subsequent phases of the HSGT Project. 

City of Chattanooga 

Comment 11-18-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 14 February 2017

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benefit to business travel and tourism as visitors and residents 

could travel from Atlanta to downtown Chattanooga and then ride 

the passenger rail to the other attractions and employment centers 

in Chattanooga. The three build alternatives have the same 

destinations within Chattanooga Metropolitan Airport and the 

downtown. The City of Chattanooga and CDOT is pleased that 

under the leadership of the FRA, GDOT and TDOT that this first 

major milestone towards fast and reliable ground transportation 

between Atlanta and Chattanooga is coming to completion. The 

City looks forward to continued participation in the Tier 2 EIS 

process and hopes to be an engaged and helpful partner to bring 

this project to fruition. Sincerely, Mayor Andy Berke.”

37 Joyce 

Stanely, 

MPA

United States 

Department of 

the Interior

“Dear Mr. Winkle:

The U.S. Department of the Interior (Department) has reviewed the 

Tier 1 Draft Environmental Impact Statement (EIS) for the AtlantaChattanooga High Speed Ground Transportation Project. We offer 

the following comments for your consideration:

Section 4(f) and Section 6(f) Resources

The Tier 1 Draft EIS combines the U.S. Department of 

Transportation (USDOT) Act Section 4(f) and the Land and Water 

Conservation Fund (LWCF) Act Section 6(f) analysis under a joint 

discussion throughout the document. The Draft EIS provides 

sufficient Tier 1 preliminary detail that addresses the requirements 

of the Section 4(f) and the LWCF Section 6(f) processes.

As noted in the Tier 1 Draft EIS, the analysis contained within the 

document focuses on the broader land use implications of the 

alternatives on a conceptual corridor level. Specific alignments 

and associated resource identification are deferred until the Tier 2 

EIS phase. As a result, the Department will defer Section 4(f) and 

LWCF Section 6(f) concurrence until the completion of the Tier 2 

analysis.

National Park Service - Chattahoochee River National Recreation 

Area 

The Chattahoochee River National Recreation Area (CRNRA) is a 

heavily used recreational resource that attracts over 3 million 

visitors a year, approximately a third of whom engage in some 

form of water-based recreation, including boating, fishing, 

canoeing, kayaking, rowing, tubing and swimming. The National 

Park Service’s (NPS) principal concern related to recreational use 

of the river is public safety. Subsequent analysis should address 

the safety of water-based recreation within CRNRA, including an 

evaluation of the alternatives and the associated construction of 

any structures that have the potential to impact the river. 

The environmental affects of severe bank undercutting and erosion 

concerns the NPS because it leads to long-term habitat alterations 

that may negatively impact aquatic species. In particular, future 

analysis should evaluate the impact of construction and structures 

on organisms that benefit from a gravel or rocky substrate, 

including trout, shoal bass, mussels, and macroinvertebrates. In 

addition, an evaluation of the alternatives for 

Further coordination with local, State, and Federal resource agencies, 

including those under the U.S. Department of the Interior, would occur during 

subsequent phases of the HSGT Project. The U.S. Department of the 

Interior’s resources of concern and proposed best management practices 

and mitigation and avoidance activities outlined in the response letter dated 

November 21, 2016 would be considered a starting point for further 

discussion and potential analysis within any planning, environmental, and 

conceptual design work performed during subsequent phases of the HSGT 

Project. The resources and concerns noted in the letter also provide the 

Georgia Department of Transportation and the FRA with awareness of 

particular issues within the corridors that may be useful for planning activities 

for other transportation projects that may fall within the parameters of the 

three Build Alternative Corridors that were evaluated in the DEIS. 

DOI Comments 11-21-

2016

DEIS Errata ID 

14 (Section 

3.7.6)

DEIS Errata ID 

15 (Section 

3.9.3.2)

DEIS Errata ID 

19 (Section 

3.9.7)

DEIS Errata ID 

20 (Table 3-25)

DEIS Errata ID 

21 (Section 

3.10.3)

DEIS Errata ID 

22 (Section 

3.10.5)
Atlanta

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construction/structures that have the potential to alter stream 

hydrology should consider the future impacts of bank erosion and 

the growing cost of measures taken to protect private and public 

property and facilities.

The NPS encourages the FRA and GDOT to use native grass 

seed or native vegetation for stabilizing road shoulders and 

streambanks at all stream crossings. Non-native species are 

easily transported downstream in the tributaries and can start new 

colonies of invasive species in the CRNRA. 

NPS encourages the FRA and GDOT to avoid using storm water 

control devices that contain plastic mesh or matting near the 

stream crossings. The mesh material is harmful to waterfowl and 

other bird species that inhabit the CRNRA and congregate and 

feed at the stream edges of the tributaries.

Visual and noise impacts to the park need to be topics addressed 

in the Tier 2 EIS. Natural and cultural sounds are integral 

components of the suite of resources and values that NPS 

managers are charged with preserving and restoring. NPS 

evaluates federal actions which may impact the human and natural 

environment within our parks with respect to our Organic Act 

mandates, including “...to conserve the scenery and the natural 

and historic objects and the wildlife therein and to provide for the 

enjoyment of the same in such a manner and by such means as 

will leave them unimpaired for the enjoyment of future 

generations.” The “scenery,” includes the natural soundscape, as 

well as the landscape (NPS 2006). NPS Director’s Order 47 

delegates to the parks the responsibility to preserve natural 

soundscapes and eliminate or mitigate inappropriate noise 

sources.

The acoustic environment of a national park, like air, water, or 

wildlife is a valuable resource that can easily be degraded or 

destroyed by inappropriate sound levels and frequencies. Intrusive 

sounds are of concern to the management of national parks 

because they can impede the ability to accomplish the NPS 

mission of resource protection. Visitors at many NPS units come 

with expectations of seeing, hearing, and experiencing phenomena 

associated with a specific natural or cultural environment, yet in 

many cases these environments are being increasingly impacted 

by artificial sounds.

Page 3-64, Upper Chattahoochee section -The Chattahoochee 

River does begin in northeast Georgia, but is does not begin near 

the Tennessee border. The headwaters are at Chattahoochee 

Gap, north of Helen, Georgia and within approximately 10 miles of 

the North Carolina border. Major tributaries in the vicinity of the 

project are Sope, Nancy, Rottenwood, Whitewater, and Long 

Island. 

Trail of Tears National Historic Trail

As noted, the Tier 1 Draft EIS identifies the Trail of Tears National 

Historic Trail (NHT) as being located within the alternatives 

currently under consideration. As the Federal administrators of this 
Atlanta

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National Historic Trail, NPS requests that impacts to the Trail of 

Tears NHT, and its associated sites and viewshed, be considered 

during future planning and analysis for this project. For continued 

consultation and coordination with NPS issues, please contact 

Steven Wright, NPS, Southeast Regional Office, Atlanta Federal 

Center, 1924 Building, 100 Alabama Street, SW., Atlanta, Georgia, 

30303, telephone (404) 507-5710. 

Coordination History with U.S. Fish and Wildlife Service (FWS) are 

as follows: 

August 22, 2007. A Notice of Intent was published in the Federal 

Register (Vol. 72, No. 162, Pages: 47121-47122). The Federal 

Highway Administration (FHWA) and Federal Railroad 

Administration (FRA) will be jointly preparing an Environmental 

Impact Statement with Georgia Department of Transportation 

(GDOT) and Tennessee Department of Transportation (TDOT) on 

the impacts related to the proposed project.

August 23, 2007. We received a notice from the Assistant Director 

Fisheries and Habitat Conservation regarding a Notice of Intent for 

a 110-Mile High-Speed Ground Transportation Corridor from 

Atlanta to Chattanooga. The Department notified our Regional 

Office on September 10, 2007, that we would work with GDOT to 

assess the Department’s concerns related to the project.

March 28, 2008. We received a letter from GDOT dated March 14, 

2008, requesting the Department to become a participating agency 

in coordination with the FRA, FHWA, and GDOT.

August 27, 2008. We received a letter from GDOT which 

acknowledged the Department’s participation in the planning 

process and included a list of contacts of other 

organizations/agencies involved in the project planning.

June 14, 2010. The Department received a letter from GDOT 

dated June 10, 2010, containing a Revised Coordination Plan 

Version (2.0): May 2010.

July 26, 2010. The Department sent a letter to GDOT, accepting 

the role as a participating agency in the project planning process.

August 5, 2010. The Department received a letter from GDOT 

dated August 2, 2010, containing a list of the participating agencies 

for the project’s National Environmental Policy Act (NEPA) 

planning process.

September 8, 2010. The Department received an early 

coordination letter from GDOT dated September 3, 2010.

September 13, 2010. We received a letter from GDOT dated 

September 10, 2010, requesting the Department’s participating in 

a screening meeting to be held on September 23, 2010.

October 19, 2010. The Department participated in a meeting 

focused on introducing the project to participating agencies.

November 19, 2010. The Department submitted a letter to GDOT 

in response to their early coordination request, listing endangered 

and threatened species concerns related to the proposed project 

alignments. We requested that avoidance and minimization 

options be enacted for those listed species along the project 
Atlanta

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corridor. The Department also requested several specific items 

related to reducing impacts to listed species: 1) GDOT consider 

clear-spanning any crossings of sensitive waters (in areas of 

designated critical habitat and where listed aquatics occur), 2) 

stormwater measures be enacted in the Etowah River system, and 

3) the population of Tennessee Yellow-eyed Grass be avoided 

where it occurs near the US 411 / I-75 interchange

July 15, 2014. The Department received a letter from FHWA to 

FRA dated July 15, 2014, rescinding their role as a co-lead agency 

and changed to a participating agency.

October 13, 2016. The Georgia Ecological Field Office, Athens, 

GA, received notification from the Assistant Director of Ecological 

Services request for comments on the Draft Tier I Environmental 

Impact Statement.

The last coordination for the proposed project occurred with our 

office in September 2010. Since that coordination, there have been 

several new species listed and species previously listed have had 

their ranges expanded in Georgia. We would request an updated 

ArcGIS shapefile/layer or similar product of the 1,000-foot width of 

each of the three alignments discussed in the draft EIS.

The Department received a 2014 letter from Georgia Division of 

FHWA rescinding their role as a co-lead for this project. Is FHWA 

still a co-lead agency? If not, please update any reference to 

FHWA as a co-lead federal agency in the final EIS and any 

appendices where appropriate.

Protected Lands (Section 3.7). Each of these alignments has the 

potential to impact protected conservation lands that appear to 

have not been included in your analysis and could include 

conservation easements, conservation banks, and mitigation sites. 

Please be aware the sites should be avoided if possible and any 

impacts to these sites (as with other federal lands including Forest 

Service, Park Service) would have a higher mitigation ratio than 

typical impacts to unprotected lands to offset the impacts to these 

lands designated as protected for natural resources. In Section 

3.7.5 [Potential Mitigation], please note that the cost of mitigating 

these impacts, if a monetary mitigation is chosen will be higher 

than typical ratios of unprotected lands. Water Resources (Section 

3.9). 

Please be aware that each of the three alignments cross through 

sensitive waters in some portions of the Upper Coosa (Etowah, 

Oostanaula, Coosawattee, and Conasauga). There are 

designated critical habitats for listed aquatics in portions of the 

rivers that will have either direct or indirect impacts by the project. 

Also, there are portions of each alignment that travel through 

watersheds identified as high priority during the 2015 revision of

Georgia’s State Wildlife Action Plan. These watersheds were 

identified as high priority based on the number of high priority 

aquatic species populations present in the watershed and the rarity 

of those species. There are also rivers in the region that are cold 

water and listed as trout streams. These sensitive water resources 
Atlanta

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host listed or at-risk aquatic as well as a food-base for listed bats 

within the area. In areas where there will be increases of 

impervious surfaces (including rail lines, storage, maintenance, 

inspection facilities, stations, parking, new connecting roadways, 

and improvements to existing roadways), we request that the 

project developers consider efforts to ameliorate the effects of 

stormwater runoff and impacts to water temperature to any 

receiving waters.

Please consult our office under provisions of the Fish and Wildlife 

Coordination Act regarding any permanent or temporary impacts 

related to the project construction as well as post-construction 

impacts to water resources. This would include construction 

activities using temporary work bridges, jetties, bank armoring or 

reinforcement, and erosion and sedimentation concerns. Because 

of karst geology and cave habitats along each of the alignments, 

please determine what geotechnical assessments are needed to 

ensure that the project would not pollute groundwater through 

natural fissures or during blasting/drilling activities.

Biological Resources (Section 3.10).

Comments specific to Table 3-25: I am unsure how this table is 

organized, but listing species by scientific name within each taxon 

group might be the easiest for those familiar with the species to 

assess the list for missing or inaccurate information. Does the 

State status listed in the Table refer to Georgia or Tennessee or 

both? Please clarify this information. Please cross-check the state 

listings for Georgia, several appear to be missing or inaccurate.

Northern Long-eared Bat is now listed as Threatened. Also, the 

range should be updated to include all counties within the project 

alignment (including Tennessee).

Rafineque's Big-eared Bat could occur along all three alignments. 

The range for this species is expected in the Blue Ridge, Ridge 

and Valley, and Southwestern Appalachians. Red-cockaded Woodpecker does have a historical range in the 

northwestern part of Georgia; however, the species no longer 

occurs in this region and would not be of concern for any of the 

alignments.

In the table the scientific name for Freckled Darter is misspelled. 

Please correct to read Percina lenticula.

Both Monkeyface Orchid (Threatened) and Georgia Rockcress 

(Threatened) are now listed species. Please update the table to 

reflect that information. Please note that White Fringeless Orchid 

and Monkeyface Orchid are the same species (Platanthera 

integrilabia), with differing common names used by each state. 

Additionally, please note that Michaux’s Sumac and Dwarf Sumac 

are the same species (Rhus michauxii). Please combine each of 

these into single rows.

Additional Comments related to Section 3.10:

Please be aware that there are over 100 species that are currently 

petitioned under the Endangered Species Act that occur or have 

occurred in Georgia. There are several species that have the 
Atlanta

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potential to occur within the project corridor and could be listed 

before the project or project design will be completed. Our office 

will attempt to make recommendations, as early as possible, to 

minimize impacts and be protective of these species during our 

consultation with GDOT.

The Etowah HCP (http://etowahaquatichcp.org/), although not 

formally adopted by the Department as a Habitat Conservation 

Plan, gives guidance for the protection of water quality and listed 

aquatics within the Etowah River watershed. Please use these 

guides for stormwater protections within the Etowah and in areas 

draining to critical habitats for listed aquatics. Specifically assess 

Section 4 of the following report, which gives guidance for post-

development stormwater management 

(http://www.etowahaquatichcp.org/research/documents/tech_rpt_s

tormwater_8_20_07.pdf).

In Section 3.10.5, the start of the second paragraph states 

potential mitigation strategies include...These efforts would be 

defined by the Department as minimization efforts (i.e. to minimize 

the impact to listed species and their habitats). For unavoidable 

impacts to listed species and their habitats, we would request that 

FRA consider requiring conservation banking and in-lieu fee 

mitigation. Conservation credits are currently available for impacts 

to Cherokee Darters at the Deerleap Conservation Preserve. 

Please consider in-lieu fee or in-kind mitigation for other aquatics 

and bats. There is a mechanism in place to accept in-lieu 

mitigation with The Conservation Fund for impacts to bat habitat 

and with The Nature Conservancy for impacts to aquatics.

Although the Draft EIS states that a large portion of each corridor 

alternative will occur within the existing right-of-way, there are 

occurrences of listed species within the existing right-of-way of I-

75. We have records of critical habitat within and along both the 

Rome/I-75 and the East Corridors. These habitats should be 

avoided.

If your project will directly or indirectly affect hardwood forests, 

please conduct vegetation surveys to determine the level of 

consultation necessary with our agency, in addition to developing 

appropriate avoidance, minimization, and mitigation measures, if 

appropriate. If the project will directly or indirectly affect caves or 

other cave-like structures, please contact our office to assess 

impacts to these resources as maternity roost for Gray Bats or 

hibernacula for Northern Long-eared Bats and other at-risk bat 

species. All listed bats and other at-risk bat species have been 

documented using man-made structures as roosts. Please 

complete inspections of all bridges, culverts, and structures that 

could be impacted by the project to determine if the structure is 

being utilized as a roost by bats. In addition, in sensitive areas, 

vibrations or blasting from construction activities could impact 

protected bats and nearby roosts. Please assess the trade-offs of 

using traditional and alternative construction methods and time of 

day restrictions for driving piles and other activities with high noise 
Atlanta-Chattanooga HSGT Tier 1 DEIS 20 February 2017

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or vibrations.

As the proposed project design is developed, please consider 

assessing design measures to minimize impacts to terrestrial 

wildlife for the at-grade portions of the proposed alignments and 

birds and bats for all alignments, especially along commonly used 

flight paths and movement/migration corridors. It would be 

beneficial to conduct an analysis of potential mortality and 

fragmentation of habitat for species of concern.

Because a purpose of the proposed project is to enhance 

economic growth throughout the Project Area, please consider 

additional analyses for the Tier 2 NEPA or once the preferred 

alternative is selected (Section 3. 11). Please assess the project's 

impacts to listed species related to interrelated and interdependent 

actions. This should include any predictions or inclusions of the 

proposed project in state, county, municipal, or city planning 

documents for development along the proposed project alignment. 

This assessment should catalog likely changes in habitat or 

impervious surface in those areas relative to the baseline 

conditions. If the project is expected to require the relocation of 

utility lines, other service lines, or existing facilities, please include 

the impacts (direct and indirect) on the listed species as a result of 

those impacts.

The Department has a continuing interest in working with the FRA, 

GDOT, and TDOT to ensure that project impacts to resources of 

concern are adequately addressed. If you have any questions or 

require further information, please contact Carrie Straight, at (706) 

613-9493, ext. 227. I can be reached via email at 

joyce_stanley@ios.doi.gov or at (404) 331-4524. 

38 Christopher 

A. 

Militscher

United States 

Environmental 

Protection 

Agency, NEPA 

Program Office 

Resource 

Conservation 

and 

Restoration 

Division

Pursuant to Section 309 of the Clean Air Act (CAA) and Section 

102(2)( C ) of the National Environmental Policy Act (NEPA), the 

U.S. Environmental Protection Agency (EPA) reviewed the Draft 

Environmental Impact Statement (DEIS) for the Tier 1 

Environmental Impact Statement for the Atlanta to Chattanooga 

High Speed Ground Transportation (HSGT) Project, developed by 

the Federal Railroad Administration (FRA), Georgia Department of 

Transportation (GDOT) and Tennessee Department of 

Transportation (TDOT) of "Project Team". On June 10, 2010, the 

GDOT requested that the EPA act as participating agency in the 

development of the DEIS and on July 9, 2010, we accepted the 

invitation. On October 4, 2010, the EPA provided a comment letter 

regarding the GDOT's "Technical Memorandum for Screening 

Methodology and Criteria", dated September 2010. The stated 

purpose of the project is to enhance intercity mobility and 

economic growth throughout the Project Area between the 

metropolitan areas and the airports of Atlanta, Georgia, and 

Chattanooga, Tennessee, by providing faster and more reliable 

ground transportation service to the public as an alternative to 

highway, intercity bus, and air travel in a manner that is safe and 

cost-effective, while avoiding, minimizing, and mitigating impacts 

on the human and natural environment. This Tier 1 EIS is a 

Further coordination with local, State, and Federal resource agencies, 

including the U.S. Environmental Protection Agecy, would occur during 

subsequent phases of the HSGT Project. The U.S. EPA’s resources of 

concern and proposed best management practices and mitigation and 

avoidance activities outlined in the response letter dated November 15, 2016 

would be considered a starting point for further discussion and potential 

analysis within any planning, environmental, and conceptual design work 

performed during subsequent phases of the HSGT Project. The resources 

and concerns noted in the letter also provide the Federal Railroad 

Administration (FRA), the Georgia Department of Transportation (GDOT), 

and the Tennessee Department of Transportation (TDOT) with awareness of 

particular issues within the corridors that may be useful for planning activities 

for other transportation projects that may fall within the parameters of the 

three Build Alternative Corridors that were evaluated in the DEIS. 

Per the recommendations in the response letter dated November 15, 2016 

we will address the following issues in the FEIS:

1. Climate change adaptation and mitigation section regulatory context 

will be added to the ROD. All other climate change adaptation and 

mitigation analysis would occur during subsequent phases of the 

HSGT Project;

EPA Comments 11-15-

2016

Section 2.4.3 of 

the Record of 

Decision

DEIS Errata ID 3 

(Section 0.3 and 

Table 0-3)

DEIS Errata 11

(Section 3.4.2

and Section 

3.4.6)

DEIS Errata 12

(Section 3.6 and 

Section 3.6.1)

DEIS Errata 13

(Section 3.6.6)

DEIS Errata 16 

(Table 3-24)
Atlanta-Chattanooga HSGT Tier 1 DEIS 21 February 2017

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Addressed in 

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program-level document, which is an EIS that is prepared when 

large geographic areas are being addressed for proposed 

improvements, allowing the project sponsor to review reasonable 

HSGT corridors, general environmental conditions, and potential 

impacts. This Tier 1 EIS considered 15 unique corridors extending 

from Hartsfield Jackson Atlanta International Airport (HJAIA) to 

downtown Chattanooga. The 15 corridors were subjected to a 

screening process as part of the development process for the 

corridors. Three (3) corridors were moved forward for further 

consideration, which are the I-75 Corridor, I-75/Rome Corridor and 

the Eastern Corridor. During the next phase of the NEPA process, 

the FRA plans to develop a Tier 2 EIS that will refine the evaluation 

to alignments within the Tier 1 Preferred Corridor Alternative and 

will then select a Preferred Alignment Alternative. Overall, the EPA 

is generally supportive of the project and the FRA, GDOT and 

TDOT's efforts to address the region's transportation issues 

through intercity passenger rail. The EPA believes that passenger 

rail is potentially a more sustainable and greener approach to 

addressing the region's growing traffic congestion and could 

potentially reduce the region's air pollutants. However, the EPA is 

concerned because of the lack of discussion regarding climate 

change and the project's impact related to greenhouse gas 

emissions (GHG). The EPA notes that the Council of 

Environmental Quality's (CEQ) recently released guidance to 

address climate change and GHG emissions in NEPA documents 

entitled: "Final Guidance for Federal Departments and Agencies 

on Consideration of Greenhouse Gas Emissions and the Effects of 

Climate Change in National Environmental Policy Act Reviews" 

(August 1, 2016). Besides the climate change and GHG concerns, 

the EPA also has environmental concerns regarding air quality and 

cumulative effects that are discussed in the detailed comments 

(See enclosure). The EPA notes that the FRA did not identify a 

Preferred Corridor Alternative in the DEIS, but will select a 

Preferred Corridor Alternative in the combined Tier 1 Final EIS 

(FEIS)/Record of Decision (ROD). Therefore, the EPA has rated 

all of the Action Alternatives within the in DEIS as "EC-2", 

indicating that we have environmental concerns with all of the 

Action Alternatives with additional information requested for a final 

document. The EPA has rated the No Action Alternative as a "LO" 

indicating we have a general lack of objections. The EPA 

appreciates the opportunity to provide comments on the proposed 

Atlanta to Chattanooga HSGT DEIS and looks forward to working 

with you to address our concerns. If you have any questions 

regarding our comments, please contact Ms. Jamie Higgins, of my 

staff, at (404) 562-9681, or by e-mail at Higgins.Jamie@epa.gov. 

Sincerely, Christopher A. Militscher 

From our review of the Tier 1 DEIS, the three (3) corridors that 

were moved forward for further consideration are as follows:

• The 1-75 Corridor Alternative is 128 miles and begins on the east 

side of HJAIA at the proposed HJAWSouthern Crescent 

2. High, Medium, and Low parameters will be defined;

3. The I-75 HOT lane project is outside of the HSGT Project study area;

4. The discussion under the Air Quality section of the FEIS will be 

expanded from what is included in the DEIS and additional 

information concerning the air quality conformity determination 

deferment to Tier 2 NEPA analysis will be provided. A disclosure of 

expected data needed for this determination will also be provided in 

this section;

5. HUC runs will be confirmed and the HUC table edited to include 

fishing designations, as appropriate;

6. The ROD will clarify information concerning potential impacts to 

Clean Water Act Section 303(d) listed impared waters;

7. Exact station locations and ancillary infrastructure that would prompt 

changes in land use are not known at this time. Additional 

coordination with local land use planning authorities would occur 

during subsequent phases of the HSGT Project. 

DEIS Errata 17

(Section 3.9.4)

DEIS Errata 24

(Section 3.11.3)

DEIS Errata 25

(Section 

3.11.3.4)

DEIS Errata 27

(Section 6.3 and 

Table 6-4)
Atlanta

-Chattanooga HSGT Tier 1 DEIS 22 February 2017

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Addressed in 

FEIS/ROD

(HJAWSC) station, immediately adjacent to 1-75, and follows 1-75 

to a point south of the proposed downtown Atlanta station. The 

corridor continues north underground through

downtown Atlanta to 1-75 north and uses the 1-75 right-of-way 

(ROW) to the proposed Cumberland/Galleria station. It continues 

north along the 1-75 ROW to the proposed Town Center, 

Cartersville, and Dalton stations. North of 1-24 in Tennessee, the 

corridor continues along an existing CSX rail ROW to proposed 

stations at the Chattanooga Metropolitan Airport (CMA) and in 

downtown Chattanooga.

• The East Corridor Alternative is 139 miles and follows the same 

alignment as the1-75 corridor to the proposed Cartersville station. 

North of the Cartersville station, the corridor deviates from 1-75 

and continues along existing CSX ROW generally parallel to US 

411, stops at the Dalton-Chatsworth and

CMA stations, and continues to the proposed downtown 

Chattanooga station.

• The 1-75/Rome Corridor Alternative is 150 miles and follows the 

same path as the I-75 and East corridors to the proposed 

Cartersville station. From the proposed Cartersville station, the 

corridor follows US 411 to Rome, continues north along an existing 

CSX rail ROW to rejoin 1-75 between the

proposed Cartersville and Dalton stations. The corridor continues 

north along the I-75 ROW to the proposed stations at Dalton and 

CMA and in downtown Chattanooga.

Specific Environmental Concerns

1. The EPA is concerned that there is no discussion in the DEIS 

regarding climate change either in terms of resiliency or potential 

impacts. The EPA notes the CEQ's recent guidance, "Final 

Guidance for Federal Departments and Agencies on Consideration 

of Greenhouse Gas Emissions and the Effects of

Climate Change in National Environmental Policy Act Reviews" 

(August 1, 2016), which states: The analysis of climate change 

impacts should focus on those aspects of the human environment 

that are impacted by both the proposed action and climate change. 

Climate change can make a resource, ecosystem, human 

community, or structure more susceptible to many types of impacts

and lessen its resilience to other environmental impacts apart from 

climate change. This increase in vulnerability can exacerbate the 

effects of the proposed action. The EPA also notes that there was 

no greenhouse gas analysis or discussion as outlined in the CEQ

guidance (see below).

As discussed in this guidance, when addressing climate change 

agencies should consider: (1) The potential effects of a proposed 

action on climate change as indicated by assessing GHG 

emissions (e.g., to include, where applicable, carbon 

sequestration); and, (2) The effects of climate change on a 

proposed action and its environmental impacts (page 4).

Recommendation: The EPA recommends GDOT/FRA provide a 

climate change analysis within the Final EIS that addresses the 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 23 February 2017

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proposed project's impacts to the climate (i.e., GHG emissions) 

and any resiliency and adaptation measures as recommended by 

CEQ's Final Guidance.

2. On page 0-12 (Table 0-3), the FRA lists performance measures 

by impact area. The EPA believes that this table is good for giving 

a brief overview of impact areas; however, there is no definition or 

explanation of the parameters of High, Medium and Low.

Recommendation: The EPA recommends that the FRA in the 

Final EIS (FEIS) provide the parameters for defining High, Medium 

and Low with respect to potential impacts.

3. On page 2-23 (Table 2-5) of the DEIS, the FRA has listed 

highway projects in the study area; however, there is no listing of 

the I-75 High Occupancy Toll (HOT) lanes that is currently being 

constructed. The EPA also notes that there was no discussion 

regarding the I-75 HOT lanes anywhere within the DEIS. This is 

especially concerning considering all of the alternatives moved 

forward for further consideration will be built within the ROW ofl-75 

where the HOT lanes are currently being constructed.

Recommendation: The EPA recommends that the FRA disclose 

the I-75 HOT lanes and potential conflicts or impacts to all the 

alternatives planned to be carried forward. The EPA also 

recommends that the I-75 HOT lane project be included within 

Table 2-5.

4. On page 3-23 of the DEIS, the FRA states, subsequent analysis 

will include a detailed air quality assessment on the Preferred 

Alternative and the station and maintenance facilities locations are 

finalized. The analysis will evaluate Project's impact on motor 

vehicle emissions due to local traffic to and from stations and of 

locomotives and other sources operating in rail yards. Potential 

construction impacts also will be analyzed. If the Project is not 

included in the Georgia SIP, an applicability analysis will be 

performed to determine if a general conformity analysis is required. 

The EPA believes that the above statement is ambiguous and it is 

unclear if the stated "Preferred Alternative" will be evaluated for 

general conformity during the Tier 1 or Tier 2 EISs. The EPA 

understands the need for more detailed modelling and assessment 

to conduct a general conformity analysis. However, the EPA 

believes that there should be some sort of comparative analysis of 

each corridor within the Tier 1 EIS to determine which corridor 

would have the least potential impact on conformity.

Recommendation: In the Final EIS, the EPA recommends that the 

FRA expand the general conformity discussion to include a 

comparative analysis of each corridor's potential impact to 

conformity. Additionally, the EPA recommends that the FRA clarify 

when they plan to determine if and when they would conduct a 

general conformity analysis (Tier 1 or Tier 2). The EPA also 

suggests that the FRA consider an evaluation of the proposed 

project alternatives in the context of meeting the potential purpose 

of Executive Order 13045, Protection of Children from 

Environmental Health Risks and Safety Risks.
Atlanta

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Number Commenter Agency or Affiliation Comments Received Response Source

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Addressed in 

FEIS/ROD

5. On page 3-73, the FRA listed all of the hydrologic unit code 

(HUC) runs and the associated use classification, but did not list 

HUCs with the fishing designation. Please identify if this is a 

coincidence or if there are other runs not listed because they are 

not identified in Georgia Rules. The EPA notes that

Georgia does not list waters that have the fishing designation. 

They simply state that if it is not listed in the Rules, then the water 

would be classified with the fishing designation.

Recommendation: The EPA recommends that the FRA clarify in 

the FEIS the reason why all HUC runs (and designation use) that 

were not listed within the Tier I DEIS.

6. On page 3-76 of the DEIS, the FRA discusses water quality 

impacts and states, "If a Corridor Alternative is selected, detailed 

analysis in Tier 2 will determine the specific increase of impervious 

area

hat would result from the development of the selected alternative."

The EPA acknowledges this approach; however, we believe that 

there are other discriminating factors that could be considered 

when disclosing water quality impacts for each corridor.

Recommendation: The EPA recommends that the FRA describe 

water quality impacts for each corridor in terms of each corridor's 

impacts to existing Clean Water Act Section 303(d) listed impaired 

waters.

As with other impacts such as wetland acres and number of 

stream crossings, each corridor could be evaluated in terms of 

impacts to 303(d) listed waters. The EPA also recommends these 

water quality impacts be displayed in Table 6-4 within the FEIS.

7. Within the Cumulative Effects section (page 3-92), the FRA 

states, "This analysis only considered transportation improvements 

projects. Land developments of regional impact would be included 

during subsequent Tier 2 analysis of secondary and cumulative 

effects." The EPA notes that the I-75 HOT lanes project was not 

included within the cumulative effects analysis (see previous 

comment). The EPA is also concerned that land development 

impacts were not considered in the cumulative effects analysis.

The FRA acknowledges that secondary land development might 

occur around station areas, but determines that these effects 

would be the same for all corridors (page 3-92, 3 .11.3 ). The EPA 

is concerned with this assertion because some stations have 

greater potential for growth and sprawl compared to other stations. 

For example, the 1-75/Rome Corridor would have 9 stations while 

both the I-75 Corridor and East Corridor would have 8 stations, 

which could lead to the determination that the I-75/Rome Corridor 

might have more potential for developmental growth because it will 

have more

stations.

Recommendation: For the FEIS, the EPA recommends that the 

FRA include the I-75 HOT lanes project within the FEIS's 

secondary and cumulative effects analysis. The EPA also 

recommends that the FRA consider land development impacts 
Atlanta-Chattanooga HSGT Tier 1 DEIS 25 February 2017

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Addressed in 

FEIS/ROD

associated with each corridor's stations and conduct a comparative

secondary and cumulative effect analysis. Additionally, the EPA 

recommends that the FRA could describe any reasonable, 

foreseeable land development activities around the stations, which 

would also provide information for a secondary and cumulative 

effects comparative analysis between the three (3)

corridors.

39 Laci 

Coleman

Georgia 

Department of 

Natural 

Resources

“To Whom it May Concern, 

The Georgia Department of Natural Resources appreciates the 

opportunity to provide comments on the Draft EIS for this project. 

To aid in our review, we are wondering if there are any available 

GIS files (shp, kml, or kmz are preferred) for the three alternatives 

in question. 

Please let me know if you can be of assistance or if there is a 

specific project team member that we should contact. 

Thank you, 

Laci Coleman”

Google earth (kml/kmz) files for the three corridor alternatives were 

transmitted by the Georgia Department of Transportation, Division of 

Intermodal, to the Georgia Department of Natural Resources on October 28, 

2016.

GADNR Comments 10-

26-2016_data request

40 Rusty 

Garrison

Georgia 

Department of 

Natural 

Resources

“Dear Ms. Heckler, 

Thank you for the opportunity to review the High Speed Ground 

Transportation (HSGT) Proposal for an Atlanta to Chattanooga 

transportation route. Georgia Wildlife Resources Division staff has 

reviewed the executive summary, Tier 1 Draft Environmental 

Impact Statement (EIP), and DEIS appendices. We offer the 

following comments regarding your documents and the direction of 

your proposed project. 

Overall, the DEIS is a well written document that adequately 

assessed a no action alternative and a wide range of action 

alternatives. The choice of three action alternatives for further 

analysis and subsequent selection of a preferred alternative 

appears sound. 

At this level analysis for the three action alternatives, the Georgia 

Wildlife Resources Division recognizes that the 1-75 Corridor 

Alternative may be least impactful to state fish and wildlife 

resources. It is the shortest route and will follow an existing 

transportation corridor (1- 75), rather than disturbing additional soil 

and water resources. The 1-75 alternative also avoids nearly all of 

the Conasauga and Coosawattee River watersheds and their 

sensitive aquatic resources. 

We support your continuing efforts, in cooperation with the Federal 

Railroad Administration, to avoid or minimize, to the extent 

possible, the adverse impacts of this project on fish and wildlife 

resources, with special attention to federal and state-listed 

Concurrence with the methodology and conclusions of the DEIS is noted. 

Additionally, the identification of the I-75 Corridor Alternative as the likely 

alternative of least impact with regards to watersheds, fish, and wildlife 

resources has been noted. 

Further coordination with local, State, and Federal resource agencies, 

including the Georgia Department of Natural Resources and its divisions, 

would occur during subsequent phases of the HSGT Project. 

GADNR Comments 11-

22-2016
Atlanta-Chattanooga HSGT Tier 1 DEIS 26 February 2017

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threatened and endangered species. As you move forward with 

Tier 2 NEPA analysis and the identification of a preferred 

alternative, we would appreciate your consideration of our 

concerns. 

Thank you again for this opportunity to provide input into your 

planning process. If you 

have any questions regarding these comments or would like 

further technical assistance in identifying and minimizing adverse 

effects to state fish and wildlife resources. Feel free to contact the 

Georgia Wildlife Resources Division. Your point of contact will be 

Anna Yellin at anna.yellin@dnr.ga.gov and telephone 770-918-

6411. Sincerely, Rusty Garrison”

41 Anna Yellin Georgia 

Department of 

Natural 

Resources

“Dear Ms. Heckler: 

The Georgia Department of Natural Resources appreciates the 

opportunity to provide comments 

on the Draft Environmental Impact Statement for this project. This 

is in response to the 

information we received October 31, 2016. The following species 

and natural communities of 

conservation concern and conservation lands are known within the 

project area: 

Atlanta Hartsfield Jackson International Airport to southernmost 

split of Alternatives

 GA Ammodramus henslowii (Henslow's Sparrow) approx. 0.5 mi 

NE of site 

 Asplenium bradleyi (Bradley's Spleenwort) [HISTORIC] 

approx. 0.9 mi SW of site 

 Boechera missouriensis (Missouri Rockcress) approx. 2.2 mi 

SW of site 

 Buchnera americana (Bluehearts) [HISTORIC] in an 

uncertain location near the project site 

 Calystegia catesbeiana ssp. sericata (Silky Bindweed) 

approx. 1.5 mi SW of site 

 GA Cambarus howardi (Chattahoochee Crayfish) approx. 0.3 mi 

SW of site in the Chattahoochee River 

 GA Cambarus howardi (Chattahoochee Crayfish) approx. 2.9 mi 

NE of site in Sope Creek 

 GA Cambarus howardi (Chattahoochee Crayfish) in an uncertain 

location near the project site in Rottenwood/ Poplar Creek 

 GA Cambarus howardi (Chattahoochee Crayfish) approx. 0.3 mi 

NE of site in Sope Creek 

 GA Crataegus triflora (Three-flowered Hawthorn) approx. 1.2 mi 

W of site 

 GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.8 mi 

W of site 

The species and natural communities of conservation concern and 

conservation lands have been noted. More detailed analysis of impacts to 

biological resources would occur during Tier 2 studies. In addition, further 

coordination with local, State, and Federal resource agencies, including the 

Georgia Department of Natural Resources and its divisions, would occur 

during subsequent phases of the HSGT Project.

GADNR Comments 11-

22-2016_T&E species

DEIS Errata ID 

14 (Section 

3.7.6)
Atlanta

-Chattanooga HSGT Tier 1 DEIS 27 February 2017

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 GA Cyprinella callitaenia (Bluestripe Shiner) approx. 2.8 mi W of 

site in the Chattahoochee River 

 GA Cyprinella callitaenia (Bluestripe Shiner) approx. 1.2 mi W of 

site in Nancy Creek 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 2.7 mi W of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 1.7 mi SW of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 1.3 mi SW of 

site Delphinium tricorne (Dwarf Larkspur) approx. 0.8 mi W of site 

 GA Draba aprica (Sun-loving Draba) approx. 2.2 mi SW of site 

 GA Draba aprica (Sun-loving Draba) approx. 2.1 mi SW of site 

 GA Elliptio arctata (Delicate Spike) [HISTORIC] in an uncertain 

location near the project site 

 US Etheostoma scotti (Cherokee Darter) approx. 2.2 mi NE of 

site in Kellogg Creek and Unnamed Tributaries 

 US Etheostoma scotti (Cherokee Darter) approx. 1.8 mi S of site 

in Proctor Creek 

 US Etheostoma scotti (Cherokee Darter) approx. 1.4 mi SW of 

site in Proctor Creek 

 US Etheostoma scotti (Cherokee Darter) approx. 2.5 mi SW of 

site in Westbrook Creek 

 US Etheostoma scotti (Cherokee Darter) on site in uncertain

locations within Clarke Creek and Unnamed Tributaries 

 US Etheostoma scotti (Cherokee Darter) approx. 0.4 mi SW of 

site in Tanyard Creek 

 US Etheostoma scotti (Cherokee Darter) [HISTORIC] approx. 

1.0 mi NE of site in Clarke Creek 

 US Etheostoma scotti (Cherokee Darter) [HISTORIC] approx. 

2.8 mi N of site in Kellogg Creek 

 GA Falco peregrinus (Peregrine Falcon) approx. 0.5 mi E of site 

 GA Fothergilla major (Mountain Witch-alder) approx. 1.0 mi NE 

of site 

 Hemidactylium scutatum (Four-toed Salamander) approx. 1.9 

mi S of site 

 GA Hybopsis lineapunctata (Lined Chub) approx. 2.7 mi SW of 

site in Westbrook Creek 

 Hybopsis sp. 9 (Etowah Chub) [HISTORIC] approx. 2.8 mi 

NE of site in Stamp Creek 

 Melanthium latifolium (Broadleaf Bunchflower) 

[EXTIRPATED?] from an unknown location near the project site 

 Micropterus cataractae (Shoal Bass) approx. 0.4 mi W of site 

in Nancy Creek 

 Micropterus cataractae (Shoal Bass) approx. 0.1 mi W of site 

in Peachtree Creek 

 Micropterus cataractae (Shoal Bass) approx. 1.2 mi NE of 

site in the Chattahoochee River 

 Myotis septentrionalis (Northern Myotis) approx. 2.6 mi NE of 

site 

 GA Nestronia umbellula (Indian Olive) approx. 0.3 mi NE of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 28 February 2017

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Addressed in 

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 GA Nestronia umbellula (Indian Olive) [HISTORIC] in an 

uncertain location near the project site 

 Nyctanassa violacea (Yellow-crowned Night-heron) in an 

uncertain location near the project site 

 GA Pachysandra procumbens (Allegheny-spurge) approx. 0.6 mi 

W of site 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.4 mi SW of 

site 

 Perimyotis subflavus (Tri-colored Bat) in an uncertain location 

near the project site 

 Perimyotis subflavus (Tri-colored Bat) approx. 1.8 mi SW of 

site 

 Perimyotis subflavus (Tri-colored Bat) [HISTORIC] in an 

uncertain location near the project site 

 GA Peucaea aestivalis (Bachman's Sparrow) [HISTORIC] 

approx. 0.3 mi W of site 

 Pituophis melanoleucus melanoleucus (Northern Pine 

Snake) approx. 0.7 mi SW of site 

 US Platanthera integrilabia (Monkeyface Orchid) [EXTIRPATED] 

approx. 1.7 mi NE of site 

 Plethodon websteri (Webster's Salamander) approx. 0.6 mi 

SW of site 

 Pycnanthemum curvipes (Stone Mountain Mint) approx. 1.8 

mi SW of site 

 Quadrula infucata (Sculptured Pigtoe) [HISTORIC] in an 

uncertain location near the project site in the Chattahoochee River 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.3 mi 

NE of site GA Sabatia capitate (Cumberland Rose-gentian) 

approx. 2.5 mi N of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.8 mi 

NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.8 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 2.2 mi E of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.2 mi SW of site 

 GA Schisandra glabra (Bay Star-vine) in an uncertain location 

near the project site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.5 mi W of site 

 GA Schisandra glabra (Bay Star-vine) [EXTIRPATED] approx. 

1.2 mi NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.4 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.5 mi 

N of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 29 February 2017

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Addressed in 

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SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.1 mi 

NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.9 mi 

W of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.1 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.0 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) in an uncertain 

location near the project site 

 GA Symphyotrichum georgianum (Georgia Aster) 

[EXTIRPATED?] approx. 1.2 mi SW of site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.7 mi S of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 0.2 mi SW of 

site 

 Viburnum rafinesquianum var. rafinesquianum (Downy 

Arrowwood) approx. 1.3 mi W of site 

 Zanthoxylum americanum (Northern Prickly-ash) approx. 1.4 

mi SW of site 

 Chattahoochee River National Recreation Area (NPS) on site 

 Clayton County Greenspace approx. 2.0 mi SE of site 

 Cobb County Greenspace approx. 0.2 mi NE of site 

 Cobb County Greenspace approx. 0.2 mi SW of site 

 Cobb County Greenspace approx. 0.6 mi S of site 

 Cobb County Greenspace approx. 1.2 mi SW of site 

 Cobb County Greenspace approx. 1.5 mi NE of site 

 Cobb County Greenspace approx. 1.5 mi SW of site 

 Cobb County Greenspace approx. 1.9 mi NE of site 

 Cobb County Greenspace approx. 1.9 mi SW of site 

 Cobb County Greenspace approx. 2.6 mi W of site 

 DeKalb County Greenspace approx. 2.9 mi E of site 

 Fulton County Greenspace approx. 0.2 mi NW of site 

 Fulton County Greenspace approx. 0.6 mi E of site 

 Fulton County Greenspace approx. 1.2 mi E of site 

 Fulton County Greenspace approx. 1.9 mi W of site 

 Fulton County Greenspace approx. 3.0 mi W of site 

 Kennesaw Mountain National Battlefield Park (NPS) approx. 

1.4 mi W of site GA Sabatia capitata (Cumberland Rose-gentian) 

approx. 2.5 mi N of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.8 mi 

NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.8 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 2.2 mi E of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.2 mi SW of site 

 GA Schisandra glabra (Bay Star-vine) in an uncertain location 

near the project site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 30 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 GA Schisandra glabra (Bay Star-vine) approx. 0.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.5 mi W of site 

 GA Schisandra glabra (Bay Star-vine) [EXTIRPATED] approx. 

1.2 mi NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.4 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.5 mi 

N of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.1 mi 

NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.9 mi 

W of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 1.1 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.0 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) in an uncertain 

location near the project site 

 GA Symphyotrichum georgianum (Georgia Aster) 

[EXTIRPATED?] approx. 1.2 mi SW of site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.7 mi S of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 0.2 mi SW of 

site 

 Viburnum rafinesquianum var. rafinesquianum (Downy 

Arrowwood) approx. 1.3 mi W of site 

 Zanthoxylum americanum (Northern Prickly-ash) approx. 1.4 

mi SW of site 

 Chattahoochee River National Recreation Area (NPS) on site 

 Clayton County Greenspace approx. 2.0 mi SE of site 

 Cobb County Greenspace approx. 0.2 mi NE of site 

 Cobb County Greenspace approx. 0.2 mi SW of site 

 Cobb County Greenspace approx. 0.6 mi S of site 

 Cobb County Greenspace approx. 1.2 mi SW of site 

 Cobb County Greenspace approx. 1.5 mi NE of site 

 Cobb County Greenspace approx. 1.5 mi SW of site 

 Cobb County Greenspace approx. 1.9 mi NE of site 

 Cobb County Greenspace approx. 1.9 mi SW of site 

 Cobb County Greenspace approx. 2.6 mi W of site 

 DeKalb County Greenspace approx. 2.9 mi E of site 

 Fulton County Greenspace approx. 0.2 mi NW of site 

 Fulton County Greenspace approx. 0.6 mi E of site 

 Fulton County Greenspace approx. 1.2 mi E of site 

 Fulton County Greenspace approx. 1.9 mi W of site 

 Fulton County Greenspace approx. 3.0 mi W of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 31 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Kennesaw Mountain National Battlefield Park (NPS) approx. 

1.4 mi W of site GA Sabatia capitata Cumberland Rose-gentian) 

approx. 2.5 mi N of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.8 mi 

NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.8 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 2.2 mi E of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.2 mi SW of site 

 GA Schisandra glabra (Bay Star-vine) in an uncertain location 

near the project site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.5 mi W of site 

 GA Schisandra glabra (Bay Star-vine) [EXTIRPATED] approx. 

1.2 mi NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.4 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.5 mi

N of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.1 mi 

NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.9 mi 

W of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.1 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.0 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) in an uncertain 

location near the project site 

 GA Symphyotrichum georgianum (Georgia Aster) 

[EXTIRPATED?] approx. 1.2 mi SW of site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.7 mi S of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 0.2 mi SW of 

site 

 Viburnum rafinesquianum var. rafinesquianum (Downy 

Arrowwood) approx. 1.3 mi W of site 

 Zanthoxylum americanum (Northern Prickly-ash) approx. 1.4 

mi SW of site 

 Chattahoochee River National Recreation Area (NPS) on site 

 Clayton County Greenspace approx. 2.0 mi SE of site 

 Cobb County Greenspace approx. 0.2 mi NE of site 

 Cobb County Greenspace approx. 0.2 mi SW of site 

 Cobb County Greenspace approx. 0.6 mi S of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 32 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Cobb County Greenspace approx. 1.2 mi SW of site 

 Cobb County Greenspace approx. 1.5 mi NE of site 

 Cobb County Greenspace approx. 1.5 mi SW of site 

 Cobb County Greenspace approx. 1.9 mi NE of site 

 Cobb County Greenspace approx. 1.9 mi SW of site 

 Cobb County Greenspace approx. 2.6 mi W of site 

 DeKalb County Greenspace approx. 2.9 mi E of site 

 Fulton County Greenspace approx. 0.2 mi NW of site 

 Fulton County Greenspace approx. 0.6 mi E of site 

 Fulton County Greenspace approx. 1.2 mi E of site 

 Fulton County Greenspace approx. 1.9 mi W of site 

 Fulton County Greenspace approx. 3.0 mi W of site 

 Kennesaw Mountain National Battlefield Park (NPS) approx. 

1.4 mi W of site GA Sabatia capitata Cumberland Rose-gentian) 

approx. 2.5 mi N of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.8 mi 

NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.8 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 2.2 mi E of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.2 mi SW of site 

 GA Schisandra glabra (Bay Star-vine) in an uncertain location 

near the project site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.9 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 0.5 mi W of site 

 GA Schisandra glabra (Bay Star-vine) [EXTIRPATED] approx. 

1.2 mi NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.4 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.5 mi 

N of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.1 mi 

NE of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.9 mi 

W of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.1 mi 

E of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.0 mi 

SW of site 

 GA Symphyotrichum georgianum (Georgia Aster) in an uncertain 

location near the project site 

 GA Symphyotrichum georgianum (Georgia Aster) 

[EXTIRPATED?] approx. 1.2 mi SW of site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.7 mi S of 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 33 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 0.2 mi SW of 

site 

 Viburnum rafinesquianum var. rafinesquianum (Downy 

Arrowwood) approx. 1.3 mi W of site 

 Zanthoxylum americanum (Northern Prickly-ash) approx. 1.4 

mi SW of site 

 Chattahoochee River National Recreation Area (NPS) on site 

 Clayton County Greenspace approx. 2.0 mi SE of site 

 Cobb County Greenspace approx. 0.2 mi NE of site 

 Cobb County Greenspace approx. 0.2 mi SW of site 

 Cobb County Greenspace approx. 0.6 mi S of site 

 Cobb County Greenspace approx. 1.2 mi SW of site 

 Cobb County Greenspace approx. 1.5 mi NE of site 

 Cobb County Greenspace approx. 1.5 mi SW of site 

 Cobb County Greenspace approx. 1.9 mi NE of site 

 Cobb County Greenspace approx. 1.9 mi SW of site 

 Cobb County Greenspace approx. 2.6 mi W of site 

 DeKalb County Greenspace approx. 2.9 mi E of site 

 Fulton County Greenspace approx. 0.2 mi NW of site 

 Fulton County Greenspace approx. 0.6 mi E of site 

 Fulton County Greenspace approx. 1.2 mi E of site 

 Fulton County Greenspace approx. 1.9 mi W of site 

 Fulton County Greenspace approx. 3.0 mi W of site 

 Kennesaw Mountain National Battlefield Park (NPS) approx. 

1.4 mi W of site 

GA Cambarus extraneus (Chickamauga Crayfish) in an 

uncertain location near the project site in South Chickamauga 

Creek 

 GA Cambarus extraneus (Chickamauga Crayfish) [HISTORIC] 

approx. 2.1 mi SW of site in East Chickamauga Creek 

 GA Cambarus extraneus (Chickamauga Crayfish) [HISTORIC] 

approx. 2.8 mi SW of site in Peavine Creek 

 Carex buxbaumii (Brown Bog Sedge) in an uncertain location 

near the project site 

 Carex grayi (Asa Gray's Sedge) approx. 0.3 mi SW of site 

 Carex triangularis (Fox Sedge) approx. 0.3 mi SW of site 

 Chaerophyllum procumbens (Spreading Chervil) approx. 0.2 

mi SW of site 

 Cheilanthes alabamensis (Alabama Lipfern) in an uncertain 

location near the project site 

 GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.1 mi 

NE of site 

 GA Cryptobranchus alleganiensis alleganiensis (Eastern 

Hellbender) approx. 2.4 mi NE of site in South Chickamauga 

Creek 

 Cyprinella spiloptera (Spotfin Shiner) approx. 1.1 mi NE of 

site in Peavine Creek 

 Cyprinella spiloptera (Spotfin Shiner) approx. 1.0 mi SW of 

site in West Chickamauga Creek 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 34 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Cyprinella spiloptera (Spotfin Shiner) approx. 0.1 mi SW of 

site in East Chickamauga Creek 

 Cyprinella spiloptera (Spotfin Shiner) approx. 0.3 mi E of site 

in South Chickamauga Creek 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 1.1 mi W of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 1.3 mi W of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 3.0 mi W of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 2.3 mi E of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 0.5 mi SW of 

site 

 GA Cypripedium parviflorum (Yellow Ladyslipper) approx. 1.3 mi 

W of site 

 Dalea gattingeri (Gattinger Prairie Clover) approx. 1.9 mi SW 

of site 

 Dalea gattingeri (Gattinger Prairie Clover) approx. 2.6 mi SW 

of site 

 Dalea gattingeri (Gattinger Prairie Clover) approx. 1.8 mi SW 

of site 

 Dalea gattingeri (Gattinger Prairie Clover) approx. 2.5 mi SW 

of site 

 Dasistoma macrophylla (Mullein Foxglove) approx. 1.5 mi NE 

of site 

 Delphinium carolinianum ssp. calciphilum (Glade Larkspur) 

approx. 1.9 mi SW of site 

 Delphinium carolinianum ssp. calciphilum (Glade Larkspur) 

approx. 1.8 mi SW of site 

 Delphinium carolinianum ssp. calciphilum (Glade Larkspur) 

approx. 2.5 mi SW of site 

 Delphinium tricorne (Dwarf Larkspur) in an uncertain location 

near the project site 

 Delphinium tricorne (Dwarf Larkspur) approx. 0.9 mi E of site 

 Desmognathus aeneus (Seepage Salamander) approx. 2.6 

mi SW of site 

 Dryopteris celsa (Log Fern) approx. 1.5 mi NE of site 

 Dryopteris celsa (Log Fern) approx. 0.9 mi NE of site 

 Eleocharis compressa (Spikerush) approx. 2.6 mi SW of site 

 Eleocharis compressa (Spikerush) approx. 1.9 mi SW of site 

 Eleocharis compressa (Spikerush) approx. 2.5 mi SW of site 

 GA Elliptio arca (Alabama Spike) approx. 2.7 mi E of site in the 

Coosawattee River 

 US Epioblasma metastriata (Upland Combshell) [HISTORIC] 

approx. 0.7 mi NE of site in the Conasauga River 

US Epioblasma othcaloogensis (Southern Acornshell) approx. 

2.3 mi W of site in Oothkalooga Creek 

 Erigenia bulbosa (Harbinger-of-spring) approx. 1.1 mi NE of 

site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 35 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 US Erimonax monachus (Spotfin Chub) [EXTIRPATED] approx. 

0.8 mi N of site in South Chickamauga Creek 

 Etheostoma cinereum (Ashy Darter) [EXTIRPATED] approx. 

2.3 mi NE of site in South Chickamauga Creek 

 GA Etheostoma ditrema (Coldwater Darter) approx. 0.6 mi SW of 

site in Camp Creek 

 GA Etheostoma ditrema (Coldwater Darter) approx. 1.9 mi W of 

site in Oothkalooga Creek 

 GA Etheostoma duryi (Blackside Snubnose Darter) approx. 0.7 

mi NE of site in Tiger Creek 

 Etheostoma jessiae (Blueside Darter) approx. 2.0 mi SW of site 

in Tanyard Creek 

 Etheostoma jessiae (Blueside Darter) approx. 1.1 mi NE of site 

in Peavine Creek 

 Etheostoma jessiae (Blueside Darter) approx. 0.8 mi S of site 

in Little Chickamauga Creek 

 Etheostoma jessiae (Blueside Darter) approx. 0.4 mi NE of site 

in Tiger Creek 

 Etheostoma jessiae (Blueside Darter) approx. 0.1 mi SW of site 

in East Chickamauga Creek 

 Etheostoma jessiae (Blueside Darter) approx. 2.3 mi NE of site 

in South Chickamauga Creek 

 Etheostoma jessiae (Blueside Darter) in an uncertain location 

near the project site in South Chickamauga Creek 

 GA Etheostoma rupestre (Rock Darter) approx. 0.7 mi NE of site 

in the Conasauga River 

 US Etheostoma scotti (Cherokee Darter) approx. 0.1 mi SW of 

site in Pettit Creek and Unnamed Tributaries 

 GA Etheostoma trisella (Trispot Darter) approx. 1.0 mi NE of site 

in Haig Mill Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 1.8 mi NE of site 

in the Conasauga River 

 GA Etheostoma trisella (Trispot Darter) approx. 2.7 mi E of site in 

Crane Eater Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 2.5 mi NE of site 

in Swamp Creek

 GA Etheostoma trisella (Trispot Darter) approx. 0.1 mi NE of site 

in Mill Creek 

 GA Etheostoma trisella (Trispot Darter) [HISTORIC] approx. 0.6 

mi E of site in Little Swamp Creek 

 GA Fothergilla major (Mountain Witch-alder) in an uncertain 

location near the project site 

 Glyceria acutiflora (Sharp-scaled Manna-grass) [HISTORIC] 

approx. 0.3 mi SW of site 

 Glyceria pallida (Pale Manna-grass) approx. 0.4 mi W of site 

 GA Graptemys geographica (Northern Map Turtle) approx. 2.3 

mi NE of site 

 GA Graptemys geographica (Northern Map Turtle) approx. 2.7 

mi SW of site 

 GA Graptemys geographica (Northern Map Turtle) [HISTORIC] 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 36 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

approx. 0.6 mi NE of site 

 GA Graptemys pulchra (Alabama Map Turtle) approx. 2.8 mi NE 

of site 

 GA Graptemys pulchra (Alabama Map Turtle) approx. 0.7 mi NE 

of site 

 GA Graptemys pulchra (Alabama Map Turtle) approx. 0.5 mi E of 

site 

 GA Graptemys pulchra (Alabama Map Turtle) [HISTORIC] 

approx. 0.9 mi E of site 

 US Hamiota altilis (Finelined Pocketbook) [HISTORIC] in an 

uncertain location near the project site in a tributary to the 

Conasauga River 

 Helianthus occidentalis (Barrens Sunflower) approx. 2.5 mi 

SW of site 

 Helianthus occidentalis (Barrens Sunflower) approx. 2.4 mi 

SW of site 

 GA Hemitremia flammea (Flame Chub) approx. 0.5 mi NE of site

in Lower Tiger Creek and associated tributaries GA Hemitremia 

flammea (Flame Chub) approx. 0.5 mi SW of site in an Unnamed 

Tributary to East Chickamauga Creek 

 Hiodon tergisus (Mooneye) approx. 0.6 mi E of site in the 

Coosawattee River 

 Hottonia inflata (Featherfoil) approx. 0.3 mi SW of site 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 

0.8 mi NE of site in the 

Oostanaula River 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 

0.7 mi E of site in Swamp Creek 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 

1.4 mi E of site in Drowning Bear Creek 

 Hydrophyllum macrophyllum (Largeleaf Waterleaf) approx. 

1.6 mi E of site 

 Hypericum dolabriforme (Glade St. Johnswort) approx. 2.6 mi 

SW of site 

 Hypericum dolabriforme (Glade St. Johnswort) approx. 2.5 mi 

SW of site 

 Hypericum dolabriforme (Glade St. Johnswort) approx. 1.9 mi 

SW of site 

 GA Ichthyomyzon bdellium (Ohio Lamprey) on site in East 

Chickamauga Creek (-85.14525, 34.97749 WGS84) 

 GA Ichthyomyzon bdellium (Ohio Lamprey) approx. 0.2 mi N of 

site in South Chickamauga Creek 

 GA Ichthyomyzon bdellium (Ohio Lamprey) approx. 0.8 mi S of 

site in Little Chickamauga Creek 

 Iris prismatica (Slender Blue Flag) approx. 0.9 mi SW of site 

 Iris prismatica (Slender Blue Flag) approx. 0.4 mi SW of site 

 Juncus filipendulus (Texas Plains Rush) approx. 1.8 mi SW 

of site 

 Juncus filipendulus (Texas Plains Rush) approx. 2.5 mi SW 

of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 37 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Juncus filipendulus (Texas Plains Rush) approx. 1.9 mi SW 

of site 

 Lampropeltis triangulum triangulum (Eastern Milk Snake) 

[HISTORIC] approx. 1.4 mi NE of site 

 Lampsilis fasciola (Wavy-rayed Lampmussel) approx. 0.2 mi 

N of site in South Chickamauga Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.5 mi 

E of site in Crow Valley Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.7 mi 

E of site in Poplar Spring Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.1 mi 

SW of site in Two Run Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) in an uncertain 

location near the project site in the Conasauga River 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 0.3 mi 

SW of site in Pettit Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.2 mi 

SWof site in Pettit Creek Unnamed Tributary 

 Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] in an 

uncertain location near the project site in Swamp Creek 

 GA Leavenworthia exigua var. exigua (Least Gladecress) 

approx. 2.6 mi SW of site 

 GA Leavenworthia exigua var. exigua (Least Gladecress) 

approx. 1.9 mi SW of site 

 GA Leavenworthia exigua var. exigua (Least Gladecress) 

approx. 1.8 mi SW of site 

 GA Leavenworthia exigua var. exigua (Least Gladecress) 

approx. 2.5 mi SW of site Leptoxis praerosa (Onyx Rocksnail) 

approx. 0.2 mi N of site in South Chickamauga Creek 

 Liatris squarrosa var. hirsuta (Glade Gay-feather) approx. 2.6 

mi SW of site 

 Liatris squarrosa var. hirsuta (Glade Gay-feather) approx. 1.8 

mi SW of site 

 Liatris squarrosa var. hirsuta (Glade Gay-feather) approx. 1.9 

mi SW of site 

 US Lioplax cyclostomaformis (Cylindrical Lioplax) [HISTORIC] in 

an uncertain location near the project site in Oothkalooga Creek 

 Lythrurus lirus (Mountain Shiner) approx. 0.7 mi NE of site in 

Tiger Creek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.7 mi 

W of site in Lynn Creek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 2.6 mi 

W of site in Mud Crek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.7 mi 

E of site in Swamp Creek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 2.5 mi 

NE of site in Swamp Creek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.6 mi 

E of site in Little Swamp Creek 

 GA Macrhybopsis sp. 1 (Coosa Chub) approx. 2.6 mi E of site in 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 38 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

the Coosawattee River 

 Macrhybopsis storeriana (Silver Chub) approx. 1.2 mi E of 

site in the Coosawattee River 

 Macrhybopsis storeriana (Silver Chub) approx. 0.8 mi NE of 

site in the Oostanaula River 

 Matelea obliqua (Limerock Milkvine) in an uncertain location 

near the project site 

 US Medionidus acutissimus (Alabama Moccasinshell) 

[HISTORIC] in an uncertain location near the project site in Swamp 

Creek 

 US Medionidus parvulus (Coosa Moccasinshell) [HISTORIC] 

approx. 0.7 mi NE of site in the Conasauga River 

 US Medionidus parvulus (Coosa Moccasinshell) [HISTORIC] in 

an uncertain location near the project site in Swamp Creek 

 Mertensia virginica (Virginia Bluebells) approx. 1.1 mi NE of 

site 

 Mertensia virginica (Virginia Bluebells) approx. 1.1 mi E of 

site 

 Moxostoma anisurum (Silver Redhorse) approx. 2.4 mi NE of 

site in South Chickamauga Creek 

 GA Moxostoma carinatum (River Redhorse) approx. 1.6 mi NE 

of site in the Coosawattee/ Conasauga near Confluence 

 GA Moxostoma carinatum (River Redhorse) approx. 2.4 mi NE 

of site in South Chickamauga Creek 

 GA Moxostoma carinatum (River Redhorse) approx. 0.6 mi E of 

site in the Oostanaula River 

 US Myotis grisescens (Gray Myotis) approx. 2.0 mi NE of site 

 US Myotis grisescens (Gray Myotis) approx. 0.1 mi N of site 

 US Myotis grisescens (Gray Myotis) approx. 1.1 mi NE of site 

 US Myotis grisescens (Gray Myotis) approx. 1.5 mi W of site 

 US Myotis grisescens (Gray Myotis) approx. 1.4 mi W of site 

 US Myotis septentrionalis (Northern Myotis) approx. 1.8 mi NE of 

site 

 Necturus maculosus (Mudpuppy) [HISTORIC] approx. 1.1 mi 

S of site in Little Chickamauga

Creek 

 GA Notropis ariommus (Popeye Shiner) approx. 0.2 mi N of site 

in South Chickamauga Creek 

 GA Notropis ariommus (Popeye Shiner) [HISTORIC] approx. 0.3 

mi N of site in an Unnamed Tributary to Chickamauga Creek 

 GA Notropis asperifrons (Burrhead Shiner) approx. 0.7 mi E of 

site in Swamp Creek Notropis atherinoides (Emerald Shiner) 

approx. 2.2 mi SW of site in West Chickamauga Creek 

 Notropis atherinoides (Emerald Shiner) approx. 1.1 mi E of 

site in South Chickamauga Creek 

 GA Notropis photogenis (Silver Shiner) approx. 2.4 mi NE of site 

in South Chickamauga Creek 

 Notropis volucellus (Mimic Shiner) approx. 2.3 mi NE of site 

in South Chickamauga Creek 

 Notropis volucellus (Mimic Shiner) approx. 0.1 mi N of site in 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 39 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

South Chickamauga Creek 

 Notropis volucellus (Mimic Shiner) approx. 0.1 mi SW of site 

in East Chickamauga Creek 

 Notropis volucellus (Mimic Shiner) [HISTORIC] approx. 0.5 

mi NE of site in Tiger Creek 

 GA Noturus eleutherus (Mountain Madtom) approx. 0.3 mi E of 

site in South Chickamauga Creek 

 Oldenlandia boscii (Bluets) in an uncertain location near the 

project site 

 Ophioglossum engelmannii (Limestone Adder's-tongue) 

approx. 2.5 mi SW of site 

 Orconectes forceps (Surgeon crayfish) approx. 0.8 mi NE of 

site in Tiger Creek 

 Panax quinquefolius (American Ginseng) approx. 1.0 mi W of 

site 

 Panax quinquefolius (American Ginseng) approx. 1.1 mi E of 

site 

 Panax quinquefolius (American Ginseng) approx. 2.0 mi E of 

site 

 Panax quinquefolius (American Ginseng) approx. 1.1 mi NE 

of site 

 Parietaria pensylvanica (Pennsylvania Pellitory) approx. 0.2 

mi SW of site 

 Pediomelum subacaule (Nashville Breadroot) approx. 2.6 mi 

SW of site 

 Pediomelum subacaule (Nashville Breadroot) approx. 1.9 mi 

SW of site 

 Pediomelum subacaule (Nashville Breadroot) approx. 1.8 mi 

SW of site 

 Pediomelum subacaule (Nashville Breadroot) approx. 2.5 mi 

SW of site 

 Percina sciera (Dusky Darter) approx. 0.1 mi N of site in 

Chickamauga Creek 

 Percina sciera (Dusky Darter) in an uncertain location near 

the project site Little Chickamauga Creek 

 Percina sciera (Dusky Darter) approx. 1.1 mi NE of site in 

Peavine Creek 

 Percina sciera (Dusky Darter) approx. 0.4 mi NE of site in 

Tiger Creek 

 Percina sciera (Dusky Darter) approx. 0.3 mi SW of site in 

East Chickamauga Creek 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.5 mi E of site 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.1 mi NE of 

site 

 Perimyotis subflavus (Tri-colored Bat) approx. 1.9 mi W of 

site 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.9 mi SW of 

site 

 Perimyotis subflavus (Tri-colored Bat) approx. 1.2 mi N of site 

 GA Phenacobius uranops (Stargazing Minnow) approx. 0.3 mi 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 40 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

SW of site in East Chickamauga Creek 

 GA Phenacobius uranops (Stargazing Minnow) approx. 1.0 mi 

SW of site in West Chickamauga Creek 

 GA Phenacobius uranops (Stargazing Minnow) E, 2007-10-11, 

Tiger Creek, approx. 0.8 mi NE of site 

 GA Phenacobius uranops (Stargazing Minnow) E, 2014-08-26, 

South Chickamauga Creek Upstream of Graysville Dam, on site in 

South Chickamauga Creek 

 Phlox amplifolia (Broadleaf Phlox) , 1992-07-31, , approx. 1.4 

mi W of site US Pleurobema decisum Southern Clubshell) H?, 

1997-09-06, Conasauga River Near Resaca, approx. 0.7 mi NE of 

site in the Conasauga River 

 US Pleurobema decisum (Southern Clubshell) H?, 2005-08-15, 

Oothkalooga Creek Near Calhoun, approx. 2.2 mi W of site 

Oothkalooga Creek 

 US Pleurobema georgianum (Southern Pigtoe) H, 1974-PRE, 

Oothkalooga Creek, approx. 2.3 mi W of site Oothkalooga Creek 

 US Pleurobema georgianum (Southern Pigtoe) H, 1974-PRE, 

Swamp Creek, on site 

 Pleurocera pyrenella (Skirted Hornsnail) approx. 0.2 mi N of 

site in Chickamauga Creek 

 Pleurocera pyrenella (Skirted Hornsnail) approx. 0.8 mi S of 

site in Little Chickamauga Creek 

 Pleurocera pyrenella (Skirted Hornsnail) approx. 1.0 mi SW 

of site in West Chickamauga Creek 

 Pleurocera pyrenella (Skirted Hornsnail) in an uncertain 

location near the project site in Mill Creek 

 Pleurocera pyrenella (Skirted Hornsnail) [HISTORIC?] 

approx. 0.5 mi SW of site in Peavine Creek 

 Pleurocera showalteri (Upland Hornsnail) [HISTORIC] 

approx. 0.9 mi W of site in the Oostanaula River 

 Pleuronaia barnesiana (Tennessee Pigtoe) approx. 0.8 mi 

NE of site in Tiger Creek 

 Pleuronaia barnesiana (Tennessee Pigtoe) [HISTORIC?] 

approx. 0.3 mi N of site in South Chickamauga Creek 

 Polemonium reptans (Jacobs Ladder) approx. 0.3 mi SW of 

site 

 Polemonium reptans (Jacobs Ladder) approx. 1.1 mi E of site 

 Polemonium reptans (Jacobs Ladder) approx. 1.1 mi NE of 

site 

 Polemonium reptans (Jacobs Ladder) approx. 1.4 mi E of site 

 Polemonium reptans (Jacobs Ladder) in an uncertain 

location near the project site 

 Ptilimnium costatum (Eastern Bishopweed) approx. 0.6 mi S 

of site 

 Ptychobranchus fasciolaris (Kidneyshell) approx. 0.2 mi N of 

site 

 US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 

2.7 mi E of site in the Coosawattee River 

 US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 41 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

0.7 mi NE of site in the GA 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] 

approx. 0.3 mi SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.2 mi 

SW of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.2 mi 

E of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.5 mi 

E of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.6 mi 

SE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.7 mi SE of site 

 Scutellaria leonardii (Glade Skullcap) approx. 2.6 mi SW of 

site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.2 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) in an 

uncertain location near the project site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.2 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.3 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.3 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.8 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.8 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.1 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.9 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.3 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.9 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.1 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi 

E of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 42 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.9 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.2 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.0 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 3.0 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.5 mi 

E of site 

 Silphium radula (Rosinweed) approx. 1.1 mi NE of site 

 Sorex hoyi (Pygmy Shrew) approx. 2.9 mi W of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

approx. 2.9 mi SW of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

[EXTIRPATED] approx. 2.5 mi SW of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

[EXTIRPATED] approx. 2.7 mi SW of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

[EXTIRPATED?] approx. 2.5 mi SW of site 

Conasauga River 

 Quadrula asperata (Alabama Orb) approx. 2.3 mi W of site in 

the Oostanaula River 

 Quadrula rumphiana (Ridged Mapleleaf) approx. 0.3 mi SW 

of site in the Oostanaula River 

 Quadrula rumphiana (Ridged Mapleleaf) approx. 2.0 mi NE 

of site in the Conasauga River 

 Quadrula rumphiana (Ridged Mapleleaf) approx. 0.9 mi E of site in the Coosawattee River 

 Quadrula rumphiana (Ridged Mapleleaf) [HISTORIC?] 

approx. 2.6 mi W of site Oothkalooga Creek 

 Quercus palustris (Pin Oak) in an uncertain location near the 

project site 

 Rudbeckia grandiflora (Largeflower Coneflower) approx. 1.1 

mi NE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.8 mi 

NE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.9 mi 

SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.4 mi 

NE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 43 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

approx. 1.8 mi NE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] 

approx. 0.3 mi SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.2 mi 

SW of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.2 mi 

E of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.5 mi 

E of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.6 mi 

SE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.7 mi SE of site 

 Scutellaria leonardii (Glade Skullcap) approx. 2.6 mi SW of 

site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.2 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) in an 

uncertain location near the project site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.2 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.3 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.3 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.8 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.8 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.1 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.9 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.3 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.9 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.1 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi 

E of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 44 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.9 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.2 mi 

E of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.0 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 3.0 mi 

NE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.5 mi 

E of site 

 Silphium radula (Rosinweed) approx. 1.1 mi NE of site 

 Sorex hoyi (Pygmy Shrew) approx. 2.9 mi W of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

approx. 2.9 mi SW of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

[EXTIRPATED] approx. 2.5 mi SW of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

[EXTIRPATED] approx. 2.7 mi SW of site 

 GA Spiranthes magnicamporum (Great Plains Ladies-tresses) 

[EXTIRPATED?] approx. 2.5 mi SW of site

Spiranthes ovalis var. erostellata (Self-pollinating Oval Ladies-

tresses) approx. 1.3 mi E of site 

 Sporobolus heterolepis (Prairie Dropseed) approx. 2.6 mi SW 

of site 

 Sporobolus heterolepis (Prairie Dropseed) approx. 1.8 mi SW 

of site 

 Sporobolus heterolepis (Prairie Dropseed) approx. 2.5 mi SW 

of site 

 Sporobolus heterolepis (Prairie Dropseed) approx. 1.9 mi SW 

of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 0.2 mi 

NW of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 2.0 mi 

SW of site 

GA Symphyotrichum georgianum (Georgia Aster) 

[EXTIRPATED?] approx. 2.6 mi E of site 

 GA Thalictrum debile (Trailing Meadowrue) on site (-84.91981, 

34.43000 WGS84) 

 GA Thaspium pinnatifidum (Glade Meadowparsnip) 

[EXTIRPATED] approx. 2.6 mi SW of site 

 Thryomanes bewickii (Bewick's Wren) approx. 1.8 mi E of 

site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 45 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.4 mi E of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.6 mi E of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.5 mi E of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 0.4 mi E of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 1.4 mi W of 

site 

 GA Trillium pusillum (Dwarf Trillium) approx. 1.6 mi E of site 

 GA Trillium pusillum (Dwarf Trillium) approx. 1.4 mi E of site 

 GA Trillium pusillum (Dwarf Trillium) approx. 1.7 mi E of site 

 Villosa trabalis (Cumberland Bean) [EXTIRPATED] in an 

uncertain location near the project site 

 Villosa umbrans (Coosa Creekshell) approx. 0.5 mi W of site 

in Oothkalooga Creek 

 Villosa umbrans (Coosa Creekshell) in an uncertain location 

near the project site in the Conasauga River 

 Villosa umbrans (Coosa Creekshell) approx. 0.2 mi SW of 

site in Swamp Creek 

 Villosa umbrans (Coosa Creekshell) [HISTORIC] approx. 0.9 

mi E of site in New Town Creek 

 Villosa vanuxemensis (Mountain Creekshell) approx. 0.2 mi 

N of site South Chickamauga Creek 

 Villosa vanuxemensis (Mountain Creekshell) [HISTORIC?] 

approx. 1.9 mi W of site in Mill Creek 

 Viola egglestonii (Glade Violet) approx. 2.6 mi SW of site 

 Viola egglestonii (Glade Violet) approx. 1.9 mi SW of site 

 Viola egglestonii (Glade Violet) approx. 2.5 mi SW of site 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

2.7 mi NE of site 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

2.1 mi SW of site 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

2.6 mi SW of site 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

3.0 mi W of site 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) on site 

(-84.78139, 34.24805 WGS84) 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

2.0 mi NE of site 

 Catoosa County Greenspace approx. 0.3 mi N of site 

 Catoosa County Greenspace approx. 0.5 mi N of site 

 Catoosa County Greenspace approx. 0.6 mi S of site 

Catoosa County Greenspace approx. 0.9 mi N of site 

 Catoosa County Greenspace approx. 1.0 mi N of site 

 Catoosa County Greenspace approx. 1.0 mi SW of site 

 Catoosa County Greenspace approx. 2.2 mi NE of site 

 Catoosa County Greenspace on site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 46 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Forest, sagpond (Sagpond Forest) approx. 0.2 mi SW of site 

 Forest, sagpond (Sagpond Forest) approx. 2.0 mi NE of site 

 Gordon County Greenspace on site 

 Pinus palustris - Pinus echinata - (Pinus virginiana) / Quercus 

marilandica - (Quercus prinus) / Vaccinium pallidum Woodland 

(Montane Mixed Longleaf Woodland) approx. 2.6 mi NE of site 

 Quercus (pagoda, phellos, shumardii) - Celtis laevigata / 

Cornus foemina / Podophyllum peltatum - Hymenocallis 

occidentalis Flatwoods Forest (Southern Ridge and Valley 

Calcareous Flatwoods Forest) on site 

 Quercus (pagoda, phellos, shumardii) - Celtis laevigata / 

Cornus foemina / Podophyllum peltatum - Hymenocallis 

occidentalis Flatwoods Forest (Southern Ridge and Valley 

Calcareous Flatwoods Forest) approx. 1.4 mi E of site 

 Shrub/scrub veg. sagpond (Sagpond Scrub-shrub) approx. 

0.8 mi SW of site 

 Whitfield County Greenspace on site 

 Antioch Church Cave approx. 2.0 mi E of site 

 Boyd Mountain Cave approx. 2.9 mi SW of site 

 Chapman's Cave approx. 1.2 mi N of site 

 Chert Chasm approx. 1.7 mi NE of site 

 Chickamauga Cave approx. 2.2 mi NE of site 

 Glenn Richard's Cave approx. 2.2 mi W of site 

 Goodson Bend #1 [Cave], approx. 1.9 mi NE of site 

 Goodson Bend #2 [Cave], approx. 1.9 mi NE of site 

 Howard Hughes Cave approx. 2.1 mi NE of site 

 Hunter's Cave approx. 2.1 mi SW of site 

 Impressive Fern Pud [Cave], approx. 2.2 mi NE of site 

 Jonboat Cave approx. 1.7 mi E of site 

 Lost Creek Cave approx. 2.0 mi NE of site 

 Lost Creek Cave approx. 2.2 mi NE of site 

 Maggie Cox Cave approx. 0.2 mi E of site 

 Mo Hole [Cave], approx. 0.2 mi NE of site 

 Moss Lake Cave approx. 0.7 mi E of site 

 Resaca Cave approx. 0.3 mi SW of site 

 Resaca Battlefield HS (GA DNR) on site 

 Ridge Cave approx. 2.1 mi SW of site 

 Chattahoochee NF (USFS) on site 

 Union Grove Church Cave approx. 2.0 mi E of site 

 Whiteoak Mtn Cave approx. 0.3 mi N of site 

 Yarbrough Cave approx. 0.3 mi NE of site 

 Coahulla Creek (0315010103) [SWAP High Priority 

Watershed] on site 

 Conasauga River 1 (0315010105) [SWAP High Priority 

Watershed] on site Coosawatee River 1 (0315010208) [SWAP 

High Priority Watershed] approx. 1.0 mi E of site 

 Oostanaula River 2 (0315010301) [SWAP High Priority 

Watershed] on site 

 Armuchee Creek (0315010305) [SWAP High Priority 

Watershed] approx. 2.9 mi W of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 47 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Allatoona Creek, Allatoona Lake (0315010409) [SWAP High 

Priority Watershed] approx. 2.0 mi SE of site 

 Etowah River 4, Allatoona Lake (0315010410) [SWAP High 

Priority Watershed] on site 

 Pumpkinvine Creek (0315010411) [SWAP High Priority 

Watershed] approx. 2.4 mi S of site 

 Etowah River 3 (0315010413) [SWAP High Priority 

Watershed] on site 

 Etowah River 2 (0315010415) [SWAP High Priority 

Watershed] on site 

 Chickamauga Creek (0602000108) [SWAP High Priority

Watershed] on site 

 Little Chickamauga Creek (0602000109) [SWAP High Priority 

Watershed] on site 

 Chattanooga Creek (0602000111) [SWAP High Priority 

Watershed] approx. 0.3 mi S of site 

East Corridor (N of split) 

 Acipenser fulvescens (Lake Sturgeon) on site in the 

Coosawattee River (-84.69623, 34.60420 WGS84) 

 Acorus americanus (Sweetflag) on site (-84.75361, 34.27111 

WGS84) 

 Aesculus glabra (Ohio Buckeye) approx. 1.1 mi SW of site 

 Agastache nepetoides (Yellow Giant Hyssop) on site (-

84.6959, 34.60108 WGS84) 

 Baptisia australis var. aberrans (Glade Blue Indigo) approx. 0.5 

mi SW of site 

 Camassia scilloides (Wild Hyacinth) in an uncertain location 

near the project site 

 Cambarus conasaugaensis (Mountain crayfish) approx. 2.4 mi 

NE of site in Unnamed Tributary to Holly

 Creek 

 Cambarus conasaugaensis (Mountain crayfish) approx. 2.3 mi 

E of site in Wolf Branch 

 GA Cambarus cymatilis (Conasauga Blue Burrower) approx. 2.3 

mi N of site 

 GA Cambarus extraneus (Chickamauga Crayfish) [HISTORIC] 

approx. 0.2 mi NE of site in Hurricane Creek 

 Cambarus manningi (Greensaddle crayfish) [HISTORIC] 

approx. 2.6 mi N of site in Mills Creek 

 GA Cambarus speciosus (Beautiful Crayfish) approx. 2.3 mi E of 

site in Wolf Branch 

 Cambarus stockeri (Cocoa Crayfish) in an uncertain location 

near the project site 

 Cambarus stockeri (Cocoa Crayfish) approx. 0.6 mi S of site in 

Pitner Branch 

 Cambarus stockeri (Cocoa Crayfish) approx. 3.0 mi NE of site 

in Seepage Area at Bagby Loop 

 Cambarus stockeri (Cocoa Crayfish) approx. 2.5 mi N of site in 

an Unnamed Tributary to Holly Creek 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 48 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Campeloma regulare (Cylinder campeloma) approx. 2.5 mi E 

of site in the Conasauga River 

 Chaerophyllum procumbens (Spreading Chervil) approx. 2.5 

mi SW of site 

 Cornus drummondii (Midwestern Roughleaf Dogwood) approx. 

0.2 mi E of site 

 GA Cryptobranchus alleganiensis alleganiensis (Eastern 

Hellbender) in an uncertain location near the project site in South 

Chickamauga Creek 

GA Cryptobranchus alleganiensis alleganiensis (Eastern 

Hellbender) [HISTORIC] approx. 0.8 mi S of site in Tiger Creek 

 US Cyprinella caerulea (Blue Shiner), in an uncertain location 

near the project site in Rock Creek 

 US Cyprinella caerulea (Blue Shiner) approx. 0.5 mi N of site in 

Holly Creek 

 US Cyprinella caerulea (Blue Shiner) approx. 0.7 mi N of site in 

the Conasauga River 

 US Cyprinella caerulea (Blue Shiner) [HISTORIC] in an uncertain 

location near the project site in Chicken Creek 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 2.3 mi E of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) on site (-84.99311, 

34.94281 WGS84) 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 2.8 mi NE of 

site 

 GA Cypripedium acaule (Pink Ladyslipper) approx. 0.4 mi W of 

site 

 Dasistoma macrophylla (Mullein Foxglove) approx. 1.5 mi SW 

of site 

 Delphinium tricorne (Dwarf Larkspur) approx. 0.6 mi NW of site 

 Desmognathus aeneus (Seepage Salamander) [HISTORIC?] 

approx. 2.4 mi NE of site 

 Dryopteris celsa (Log Fern) approx. 0.9 mi NE of site 

 GA Elliptio arca (Alabama Spike) approx. 1.0 mi E of site in the 

Conasauga River 

 US Epioblasma metastriata (Upland Combshell) [HISTORIC] 

approx. 1.3 mi S of site in the Conasauga River 

 US Epioblasma othcaloogensis (Southern Acornshell) 

[EXTIRPATED] approx. 0.3 mi N of site in the Conasauga River 

 Erigenia bulbosa (Harbinger-of-spring) in an uncertain location 

near the project site 

 US Erimonax monachus (Spotfin Chub) [EXTIRPATED] 

approx. 2.0 mi SW of site in South Chickamauga Creek 

 Etheostoma cinereum (Ashy Darter) [EXTIRPATED] on site in 

South Chickamauga Creek (-85.14570, 34.97817 WGS84) 

 GA Etheostoma ditrema (Coldwater Darter) approx. 1.9 mi N of 

site in Cohutta Springs and Spring Run 

 GA Etheostoma ditrema (Coldwater Darter) [HISTORIC?] 

approx. 2.7 mi NE of site in Estelle Spring 

 GA Etheostoma ditrema (Coldwater Darter) [EXTIRPATED] 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 49 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

approx. 2.5 mi N of site in Sand Spring 

 GA Etheostoma duryi (Blackside Snubnose Darter) approx. 2.6 

mi S of site in Tiger Creek 

 Etheostoma jessiae (Blueside Darter) approx. 0.5 mi NE of site 

in Hurricane Creek 

 Etheostoma jessiae (Blueside Darter) approx. 0.8 mi S of site 

in Tiger Creek 

 Etheostoma jessiae (Blueside Darter) on site in South 

Chickamauga Creek (-85.14527, 34.97860 WGS84) 

GA Etheostoma rupestre (Rock Darter) in an uncertain location 

near the project site in Coahulla Creek 

GA Etheostoma rupestre (Rock Darter) in an uncertain location 

near the project site in the Conasauga River 

 GA Etheostoma rupestre (Rock Darter) approx. 0.3 mi N of site 

in the Conasauga River 

 GA Etheostoma trisella (Trispot Darter) approx. 1.2 mi W of site 

in Rock Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 1.6 mi W of site 

in Sugar Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 1.2 mi S of site in 

the Conasauga River 

 GA Etheostoma trisella (Trispot Darter) approx. 2.5 mi W of site 

in Dry Creek GA Etheostoma trisella (Trispot Darter) in an 

uncertain location near the project site in Pinhook Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 1.1 mi W of site 

in Mill Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 0.9 mi SE of site 

in Coahulla Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 0.1 mi W of site 

in Coosawattee River 

 GA Etheostoma trisella (Trispot Darter) approx. 0.6 mi W of site 

in Salacoa Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 0.5 mi N of site in 

Holly Creek 

 GA Etheostoma trisella (Trispot Darter) approx. 0.3 mi NE of site 

in the Conasauga River 

 GA Etheostoma trisella (Trispot Darter) approx. 2.7 mi NE of site 

in an Unnamed Tributary to Conasauga River 

 Eurycea aquatica (Brown-backed Salamander) approx. 2.3 mi 

W of site 

 GA Gomphus consanguis (Cherokee Clubtail) approx. 0.8 mi S 

of site in Tiger Creek 

 GA Graptemys geographica (Northern Map Turtle) in an 

uncertain location near the project site 

 GA Graptemys geographica (Northern Map Turtle) [HISTORIC] 

approx. 2.3 mi NE of site 

 GA Graptemys pulchra (Alabama Map Turtle) [HISTORIC] 

approx. 2.3 mi NE of site 

 GA Graptemys pulchra (Alabama Map Turtle) [HISTORIC] in an 

uncertain location near the project site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 50 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 GA Haliaeetus leucocephalus (Bald Eagle) approx. 1.2 mi E of 

site 

 US Hamiota altilis (Finelined Pocketbook) approx. 1.3 mi W of 

site in Rock Creek 

 US Hamiota altilis (Finelined Pocketbook) approx. 0.1 mi NE of 

site in the Conasauga River 

 US Hamiota altilis (Finelined Pocketbook) [HISTORIC] in an 

uncertain location near the project site in Coahulla Creek 

 US Hamiota altilis (Finelined Pocketbook) [HISTORIC] approx. 

1.6 mi S of site in Holly Creek 

 Helianthus smithii (Smith Sunflower) approx. 2.6 mi SE of site 

 GA Hemitremia flammea (Flame Chub) approx. 0.4 mi N of site 

in a tributary to Sugar Creek 

 GA Hemitremia flammea (Flame Chub) approx. 1.1 mi N of site 

in Dry Creek 

 GA Hemitremia flammea (Flame Chub) approx. 0.8 mi S of site 

in Lower Tiger Creek and Tributaries 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] in an 

uncertain location near the project site in an Unnamed 

Coosawattee River Tributary 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 

0.1 mi W of site in the Coosawattee River Tributary 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] on site in 

a Holly Creek Tributary (-84.74768, 34.72164 WGS84) 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 

0.4 mi W of site in Rock Creek 

 Hydrophyllum macrophyllum (Largeleaf Waterleaf) on site (-

84.69634, 34.60011 WGS84) 

 Hypericum dolabriforme (Glade St. Johnswort) approx. 0.3 mi 

W of site 

 GA Ichthyomyzon bdellium (Ohio Lamprey) on site in East 

Chickamauga Creek (-85.14525, 34.97749 WGS84) 

 Juncus filipendulus (Texas Plains Rush) approx. 0.3 mi W of 

site 

Lampetra aepyptera (Least Brook Lamprey) approx. 1.4 mi N of 

site in Mills Creek 

 Lampetra aepyptera (Least Brook Lamprey) approx. 1.1 mi E 

of site in the Conasauga 

 River Lampropeltis triangulum triangulum (Eastern Milk 

Snake) [HISTORIC] approx. 0.1 mi E of site 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 2.9 mi W 

of site in Poplar Spring Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) in an uncertain 

location near the project site in an Unnamed Tributary to Sugar 

Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.4 mi W 

of site in Pettit Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.3 mi 

SW of site in an Unnamed Tributary to Pettit Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 51 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

approx. 1.6 mi W of site in Kenyon (Spring) Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] 

approx. 2.3 mi SW of site in Little Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] 

approx. 2.2 mi N of site in Mills Creek 

 Leavenworthia uniflora (Gladecress) approx. 0.3 mi W of site 

 US Lioplax cyclostomaformis (Cylindrical Lioplax) [HISTORIC] in 

an uncertain location near the project site in Coahulla Creek 

 Lythrurus lirus (Mountain Shiner) approx. 1.6 mi W of site in 

Sugar Creek 

 Lythrurus lirus (Mountain Shiner) approx. 2.5 mi W of site in 

Dry Creek 

 Lythrurus lirus (Mountain Shiner) approx. 2.6 mi S of site in 

Tiger Creek 

 Lythrurus lirus (Mountain Shiner) approx. 0.7 mi E of site in 

Coahulla Creek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 1.4 mi N 

of site in Mill Creek 

 GA Macrhybopsis sp. 1 (Coosa Chub) approx. 0.2 mi W of site in 

Mill Creek 

 GA Macrhybopsis sp. 1 (Coosa Chub) approx. 2.3 mi SW of site 

in the Conasauga River 

 GA Macrhybopsis sp. 1 (Coosa Chub) approx. 0.1 mi W of site in 

Coosawattee River 

 GA Macrhybopsis sp. 1 (Coosa Chub) [EXTIRPATED?] approx. 

0.2 mi NE of site in the Conasauga River 

Macrhybopsis storeriana (Silver Chub) approx. 0.1 mi NE of site in 

the Conasauga River 

 US Medionidus acutissimus (Alabama Moccasinshell) 

[HISTORIC] in an uncertain location near the project site in 

Coahulla Creek 

 Mertensia virginica (Virginia Bluebells) in an uncertain location 

near the project site 

 Moxostoma anisurum (Silver Redhorse) on site in East 

Chickamauga Creek (-85.14514, 34.97783 WGS84) 

 GA Moxostoma carinatum (River Redhorse) in an uncertain 

location near the project site in the Coosawattee River 

 GA Moxostoma carinatum (River Redhorse) approx. 2.2 mi SW 

of site in Holly Creek 

 GA Moxostoma carinatum (River Redhorse) on site in the 

Conasauga River (-84.87157, 34.73594 WGS84) 

 GA Moxostoma carinatum (River Redhorse) on site in East 

Chickamauga Creek (-85.14525 34.97789 WGS84) 

 GA Moxostoma carinatum (River Redhorse) approx. 2.3 mi NE 

of site in the Conasauga River 

 US Myotis grisescens (Gray Myotis) approx. 0.8 mi SW of site 

 US Myotis grisescens (Gray Myotis) approx. 3.0 mi SW of site 

 US Myotis grisescens (Gray Myotis) approx. 2.0 mi S of site 

 US Myotis grisescens (Gray Myotis) approx. 0.9 mi S of site 

Myotis leibii (Eastern Small-footed Myotis) approx. 3.0 mi NE of 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 52 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

site 

 GA Notropis ariommus (Popeye Shiner) in an uncertain location

near the project site in East Chickamauga Creek 

 GA Notropis asperifrons (Burrhead Shiner) in an uncertain 

location near the project site in Rock Creek 

 Notropis atherinoides (Emerald Shiner) an uncertain location 

near the project site in East Chickamauga Creek

GA Notropis photogenis (Silver Shiner) on site in East

Chickamauga Creek (-85.14523, 34.97785 WGS84) 

 Notropis volucellus (Mimic Shiner) on site in East 

Chickamauga Creek (-85.14596, 34.97843 WGS84) 

 Notropis volucellus (Mimic Shiner) [HISTORIC] approx. 2.6 mi 

S of site in Tiger Creek GA Noturus munitus (Frecklebelly 

Madtom) approx. 0.3 mi N of site 

 Orconectes forceps (Surgeon crayfish) approx. 2.5 mi S of site 

in Tiger Creek 

 Panax quinquefolius (American Ginseng) approx. 1.1 mi SW of 

site 

 Parnassia grandifolia (Largeleaf Grass-of-Parnassus) approx. 

0.2 mi N of site 

 US Percina antesella (Amber Darter) approx. 0.6 mi S of site in 

the Conasauga River 

 US Percina antesella (Amber Darter) approx. 0.3 mi N of site in 

the Conasauga River 

 US Percina aurolineata (Goldline Darter) approx. 0.1 mi W of site 

in the Coosawattee River

 US Percina aurolineata (Goldline Darter) approx. 2.3 mi E of site 

in Talking Rock Creek 

 US Percina jenkinsi (Conasauga Logperch) approx. 2.3 mi NE of 

site in the Conasauga River 

 GA Percina kusha (Bridled Darter) approx. 0.1 mi NE of site in the Conasauga River 

 GA Percina lenticula (Freckled Darter) in an uncertain location 

near the project site in Coahulla Creek 

 GA Percina lenticula (Freckled Darter) approx. 1.1 mi SW of site 

in the Coosawattee River 

 GA Percina lenticula (Freckled Darter) approx. 0.3 mi N of site in 

the Conasauga River 

 Percina sciera (Dusky Darter) approx. 2.7 mi S of site in Tiger 

Creek 

 US Percina tanasi (Snail Darter) on site in South Chickamauga 

Creek 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.1 mi S of site 

 Perimyotis subflavus (Tri-colored Bat) approx. 1.3 mi W of site 

 Perimyotis subflavus (Tri-colored Bat) [HISTORIC] approx. 2.2 

mi SW of site 

 Perimyotis subflavus (Tri-colored Bat) [HISTORIC] in an 

uncertain location near the project site 

 Perimyotis subflavus (Tri-colored Bat) [HISTORIC] approx. 1.3 

mi N of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 53 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Phacelia fimbriata (Fringed Phacelia) approx. 0.1 mi E of site 

 GA Phenacobius uranops (Stargazing Minnow) approx. 2.3 mi S 

of site in Tiger Creek 

 GA Phenacobius uranops (Stargazing Minnow) on site in South 

Chickamauga Creek 

 GA Phenacobius uranops (Stargazing Minnow) approx. 0.3 mi S 

of site in South Chickamauga Creek 

 US Pleurobema decisum (Southern Clubshell) approx. 0.1 mi NE

of site in Conasauga River 

 US Pleurobema decisum (Southern Clubshell) [HISTORIC] on 

site in Coahulla Creek 

 US Pleurobema decisum (Southern Clubshell) [HISTORIC] 

approx. 1.9 mi SW of site in the Coosawattee River 

 US Pleurobema decisum (Southern Clubshell) [HISTORIC] 

approx. 2.0 mi S of site in Holly Creek 

US Pleurobema georgianum (Southern Pigtoe) approx. 3.0 mi E 

of site in the Conasauga River 

 US Pleurobema hanleyianum (Georgia Pigtoe) approx. 2.3 mi E 

of site in the Conasauga River 

 Pleurocera pyrenella (Skirted Hornsnail) [HISTORIC?] approx. 

1.0 mi SW of site in Peavine Creek 

 Pleuronaia barnesiana (Tennessee Pigtoe) approx. 2.5 mi S of 

site in Tiger Creek 

 Polemonium reptans (Jacobs Ladder) [HISTORIC] approx. 2.3 

mi NW of site 

 Pseudacris brachyphona (Mountain Chorus Frog) approx. 2.5 

mi W of site 

 Pseudacris brachyphona (Mountain Chorus Frog) approx. 2.1 

mi SE of site 

 US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 

0.1 mi NE of site in the Conasauga River 

 US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 

1.6 mi S of site in Holly Creek 

 US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 

2.3 mi SW of site in Little Creek 

 Quadrula asperata (Alabama Orb) approx. 2.3 mi NE of site in 

the Conasauga River 

 Quadrula asperata (Alabama Orb) approx. 1.9 mi SW of site in 

the Coosawattee River 

 Quadrula rumphiana (Ridged Mapleleaf) approx. 1.1 mi E of 

site in the Conasauga River 

 Ribes curvatum (Granite Gooseberry) approx. 2.0 mi NE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) in an uncertain 

location near the project site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.2 mi 

SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.9 mi 

SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.9 mi 

E of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 54 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.5 mi 

E of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.4 mi 

W of site 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] 

approx. 1.7 mi S of site 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] 

approx. 0.3 mi SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] 

approx. 2.2 mi E of site 

 GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC?] 

approx. 1.6 mi SE of site 

 US Scutellaria montana (Large-flowered Skullcap) in an 

uncertain location near the project site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.1 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.9 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.8 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.3 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.5 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.2 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi 

N of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.8 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.9 mi 

S of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.6 mi 

SW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.0 mi 

SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi 

N of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.1 mi 

S of site 

 GA Strophitus connasaugaensis (Alabama Creekmussel) 

approx. 1.3 mi W of site in Rock Creek 

 GA Strophitus connasaugaensis (Alabama Creekmussel) 

approx. 2.5 mi E of site in the Conasauga River 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 55 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 GA Strophitus connasaugaensis (Alabama Creekmussel) 

approx. 2.4 mi N of site in Holly Creek 

 US Symphyotrichum georgianum (Georgia Aster) approx. 0.2 mi 

NW of site 

 US Symphyotrichum georgianum (Georgia Aster) approx. 2.7 mi 

E of site 

 US Symphyotrichum georgianum (Georgia Aster) approx. 0.8 mi 

W of site 

 US Symphyotrichum georgianum (Georgia Aster) approx. 1.8 mi 

W of site 

 US Symphyotrichum georgianum (Georgia Aster) in an uncertain 

location near the project site 

 US Symphyotrichum georgianum (Georgia Aster) 

[EXTIRPATED?] approx. 2.6 mi E of site 

 Symphyotrichum novae-angliae (New England Aster) approx. 

0.7 mi W of site 

 Thryomanes bewickii (Bewick's Wren) approx. 1.7 mi SW of 

site 

 Trillium lancifolium (Lanceleaf Trillium) approx. 2.5 mi SW of 

site 

 Trillium lancifolium (Lanceleaf Trillium) [HISTORIC] approx. 0.3 

mi E of site 

 Villosa nebulosa (Alabama Rainbow) approx. 0.8 mi SW of site 

in Pitner Branch 

 Villosa nebulosa (Alabama Rainbow) approx. 0.3 mi W of site 

in Rock Creek 

 Villosa nebulosa (Alabama Rainbow) approx. 2.3 mi NE of site 

in the Conasauga River 

 Villosa trabalis (Cumberland Bean) [EXTIRPATED] approx. 1.8 

mi SW of site 

 Villosa umbrans (Coosa Creekshell) approx. 0.8 mi SW of site 

in Pitner Branch 

 Villosa umbrans (Coosa Creekshell) in an uncertain location 

near the project site in Rock Creek 

 Villosa umbrans (Coosa Creekshell) on site in an Unnamed 

Tributary to Sugar Creek 

 Villosa umbrans (Coosa Creekshell) [HISTORIC?] approx. 0.4 

mi NE of site in Wilson Creek

 Villosa vanuxemensis (Mountain Creekshell) approx. 0.9 mi S 

of site in Tiger Creek 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

0.6 mi W of site 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) in an 

uncertain location near the project site 

 Bartow County Greenspace approx. 2.7 mi E of site 

 Bartow County Greenspace approx. 2.9 mi E of site 

 Catoosa County Greenspace approx. 1.6 mi SW of site 

 Catoosa County Greenspace approx. 1.9 mi SW of site 

 Catoosa County Greenspace approx. 2.2 mi SW of site 

 Catoosa County Greenspace approx. 2.4 mi SW of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 56 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

 Catoosa County Greenspace approx. 2.9 mi SW of site 

 Catoosa County Greenspace on site 

 Cherokee County Greenspace approx. 2.7 mi E of site 

 Cherokee County Greenspace approx. 2.9 mi E of site 

 Cumberland Plateau/ridge and Valley Cave on site 

 Forest, sagpond (Sagpond Forest) approx. 3.0 mi N of site 

 Mountain spring (Mountain Spring) 1.9 mi N of site 

 Murray County Greenspace approx. 2.2 mi N of site Pinus 

palustris - Pinus echinata - (Pinus virginiana) / Quercus 

marilandica - (Quercus prinus) / Vaccinium pallidum Woodland 

(Montane Mixed Longleaf Woodland) A, approx. 1.9 mi SE of site 

 Anthony's Cave approx. 2.5 mi W of site 

 Apple Cave approx. 2.7 mi NE of site 

 Arnold Cave approx. 1.0 mi W of site 

 Baxter Cave approx. 0.5 mi E of site 

 Bradford Cave approx. 0.1 mi E of site 

 Cactus Cave approx. 2.6 mi N of site 

 Callaway Cave approx. 0.2 mi NE of site 

 Cave Hill Cave approx. 0.6 mi N of site 

 Cedar Ridge #1 [Cave] on site 

 Cedar Ridge #2 [Cave] on site 

 Cedar Ridge #3 [Cave] on site 

 Chapman's Cave approx. 2.3 mi SW of site 

 Chickamauga Cave approx. 0.8 mi SW of site 

 Fallen Oak Sink [Cave] approx. 0.6 mi S of site 

 Fincher Bluff Cave approx. 0.6 mi S of site 

 Goodson Bend #1 [Cave] approx. 1.3 mi SW of site 

 Goodson Bend #2 [Cave] approx. 1.3 mi SW of site 

 Hesitation Hole [Cave], on site 

 Howard Hughes Cave approx. 0.8 mi S of site 

 Impressive Fern Pud [Cave], approx. 0.8 mi SW of site 

 Jack Crider Cave approx. 2.0 mi NW of site 

 Jonboat Cave approx. 1.7 mi SW of site 

 Ketchum's Cave on site 

 Long's Short Cave approx. 2.3 mi W of site 

 Lost Creek Cave approx. 0.8 mi SW of site 

 Lost Creek Cave approx. 1.0 mi SW of site 

 Major Pullim's Cave approx. 0.7 mi SW of site 

 Mayben Cave approx. 0.1 mi W of site 

 McKinney Spring [Cave] approx. 0.3 mi NE of site 

 Preacher Sluder Cave approx. 1.0 mi E of site 

 Rusty Cable Cave approx. 2.2 mi NW of site 

 Sonoraville Cave approx. 1.3 mi W of site 

 Spider Cave approx. 0.4 mi E of site 

 Steep Cave approx. 2.2 mi NW of site 

 Trestle Cave on site 

 Whiteoak Mtn Cave approx. 2.5 mi S of site 

 Conasauga River 2 (0315010102) [SWAP High Priority 

Watershed] on site 

 Coahulla Creek (0315010103) [SWAP High Priority 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 57 February 2017

Summary of Public and Agency Outreach

Comment 

Number Commenter Agency or Affiliation Comments Received Response Source

Section/Table 

Addressed in 

FEIS/ROD

Watershed] on site 

 Holly Creek (0315010104) [SWAP High Priority Watershed] on 

site 

 Conasauga River 1 (0315010105) [SWAP High Priority 

Watershed] on site 

 Coosawatee River 2, Carters Lake (0315010204) [SWAP High 

Priority Watershed] approx. 1.1 mi E of site 

 Talking Rock Creek (0315010205) [SWAP High Priority 

Watershed] on site Salacoa Creek (0315010206) [SWAP High 

Priority Watershed] on site 

 Coosawatee River 1 (0315010208) [SWAP High Priority Watershed] on site 

 Etowah River 4, Allatoona Lake (0315010410) [SWAP High 

Priority Watershed] on site 

 Pumpkinvine Creek (0315010411) [SWAP High Priority 

Watershed] approx. 2.4 mi S of site 

 Etowah River 2 (0315010415) [SWAP High Priority Watershed] 

approx. 2.1 mi NW of site 

 Little Chickamauga Creek (0602000109) [SWAP High Priority 

Watershed] on site 

 Chickamauga Creek (0602000108) [SWAP High Priority 

Watershed] on site 

Rome Loop (Site Center: -85.109874, 34.306668, WGS84) 

 Acipenser fulvescens (Lake Sturgeon) approx. 0.6 mi NE of 

site in the Etowah River 

 Amblema elliottii (Coosa Fiveridge) approx. 1.9 mi NW of site in 

the Oostanaula River 

 Amblema elliottii (Coosa Fiveridge) approx. 2.5 mi N of site in 

the Oostanaula River 

 US Arabis georgiana (Georgia Rockcress) approx. 0.4 mi NW of 

site 

 Asclepias hirtella (Barrens Milkweed) approx. 2.0 mi NW of site 

 Camassia scilloides (Wild Hyacinth) approx. 1.3 mi NW of site 

 GA Cambarus fasciatus (Etowah Crayfish) approx. 2.9 mi N of 

site in Tom’s Creek 

 Carex eburnea (Black-seed Sedge) approx. 1.7 mi NW of site 

 Carex purpurifera (Purple Sedge) approx. 0.5 mi NW of site 

 Carex purpurifera (Purple Sedge) approx. 1.7 mi NW of site 

 Chaerophyllum procumbens (Spreading Chervil) approx. 1.8 

mi NW of site 

 Cheilanthes alabamensis (Alabama Lipfern) approx. 2.3 mi SE 

of site 

 Cheilanthes alabamensis (Alabama Lipfern) approx. 1.5 mi SE 

of site 

 GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.3 mi 

NW of site 

 GA Crataegus triflora (Three-flowered Hawthorn) approx. 1.8 mi 

NW of site 

 GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.5 mi 

NW of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 58 February 2017

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 GA Cypripedium acaule (Pink Ladyslipper) approx. 2.4 mi NE of 

site 

 GA Elliptio arca (Alabama Spike) approx. 1.8 mi NW of site in the 

Oostanaula River 

 US Epioblasma penita (Southern Combshell) [HISTORIC?] 

approx. 2.3 mi NW of site in the Oostanaula River 

 GA Etheostoma ditrema (Coldwater Darter) approx. 2.7 mi S of 

site in an Unnamed Tributary to Oothkalooga Creek 

 GA Etheostoma ditrema (Coldwater Darter) approx. 1.2 mi NW 

of site in an Unnamed Tributary to Woodward Creek 

 US Etheostoma etowahae (Etowah Darter) approx. 1.0 mi S of 

site in the Etowah River 

 US Etheostoma scotti (Cherokee Darter) in an uncertain location 

near the project site in Nancy

Creek and Unnamed Tributaries 

 US Etheostoma scotti (Cherokee Darter) approx. 1.1 mi NE of 

site in Pettit Creek and Unnamed Tributaries 

 GA Etheostoma trisella (Trispot Darter) approx. 1.3 mi NW of site 

in Woodward Creek 

 GA Gomphus consanguis (Cherokee Clubtail) approx. 2.5 mi N 

of site in Robbins Creek 

 GA Gomphus consanguis (Cherokee Clubtail) approx. 0.1 mi SE 

of site in Woodward Creek 

 GA Haliaeetus leucocephalus (Bald Eagle) approx. 2.3 mi S of 

site 

 Hiodon tergisus (Mooneye) approx. 0.5 mi NW of site in the 

Oostanaula River GA Hybopsis ineapunctata (Lined Chub) 

[HISTORIC] approx. 0.3 mi SE of site in the Oostanaula River 

 GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 

0.6 mi NW of site in Lynn Creek 

 Hybopsis sp. 9 (Etowah Chub) [HISTORIC] approx. 2.0 mi E of 

site in Dyke’s Creek 

 Lampropeltis triangulum triangulum (Eastern Milk Snake) 

approx. 2.5 mi W of site 

 Lampsilis straminea (Southern Fatmucket) approx. 3.0 mi E of 

site in Dykes Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 2.7 mi 

SW of site in Shoal Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 0.1 mi N 

of site in Nancy Creek 

 Lasmigona etowaensis (Etowah Heelsplitter) approx. 2.0 mi NE 

of site in Pettit Creek 

 US Leptoxis foremani (Interrupted Rocksnail) approx. 1.8 mi NW 

of site in the Oostanaula River 

 US Lioplax cyclostomaformis (Cylindrical Lioplax) [HISTORIC] in 

an uncertain location near the project site in the Oostanaula River 

 Lythrurus lirus (Mountain Shiner) approx. 2.2 mi N of site in 

Robbins Creek 

 Lythrurus lirus (Mountain Shiner) approx. 2.2 mi N of site in 

Robbins Creek 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 59 February 2017

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 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.6 mi 

NW of site in Lynn Creek 

 Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.3 mi N 

of site in the Etowah River 

 Macrhybopsis storeriana (Silver Chub) approx. 1.9 mi NW of 

site in the Oostanaula River 

 Macrhybopsis storeriana (Silver Chub) approx. 2.7 mi W of site 

in the Oostanaula River 

 Macrhybopsis storeriana (Silver Chub) approx. 1.9 mi NW of 

site in the Oostanaula River 

 US Marshallia mohrii (Coosa Barbara Buttons) approx. 2.0 mi 

NW of site 

 US Medionidus acutissimus (Alabama Moccasinshell) 

[HISTORIC] on site in Ookalooga Creek 

 GA Moxostoma carinatum (River Redhorse) approx. 1.9 mi NW 

of site in Armuchee Creek 

 GA Moxostoma carinatum (River Redhorse) approx. 0.5 mi NW 

of site in the Oostanaula River 

 US Myotis grisescens (Gray Myotis) approx. 1.6 mi NW of site 

 Myotis lucifugus (Little Brown Myotis) approx. 0.9 mi S of site 

 US Myotis septentrionalis (Northern Myotis) approx. 0.9 mi S of 

site 

 GA Pachysandra procumbens (Allegheny-spurge) approx. 0.4 mi 

NW of site 

 Panax quinquefolius (American Ginseng) approx. 1.6 mi NW of 

site 

 Panax quinquefolius (American Ginseng) approx. 1.7 mi NW of 

site 

 Perimyotis subflavus (Tri-colored Bat) approx. 2.7 mi S of site 

 Perimyotis subflavus (Tri-colored Bat) approx. 2.3 mi NE of site 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.9 mi S of site 

 Perimyotis subflavus (Tri-colored Bat) approx. 0.3 mi N of site 

 Pituophis melanoleucus melanoleucus (Northern Pine Snake) 

approx. 0.7 mi S of site 

 US Pleurobema decisum (Southern Clubshell) [EXTIRPATED?] 

approx. 1.9 mi NW of site in the Oostanaula River 

 Pleurocera showalteri (Upland Hornsnail) approx. 1.7 mi NW of 

site in the Oostanaula River 

 Polemonium reptans (Jacobs Ladder) approx. 1.7 mi NW of 

site 

 Potamogeton amplifolius (Bigleaf Pondweed) [HISTORIC] in 

an uncertain location near the project site US Ptychobranchus 

foremanianus (Rayed Kidneyshell) approx. 1.0 mi NW of site in the 

Oostanaula River 

 Quadrula asperata (Alabama Orb) approx. 1.5 mi NW of site in 

the Oostanaula River 

 Quadrula asperata (Alabama Orb) approx. 2.6 mi N of site in 

the Oostanaula River 

 Quadrula rumphiana (Ridged Mapleleaf) approx. 1.9 mi NW of 

site in the Oostanaula River 
Atlanta

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 Quadrula rumphiana (Ridged Mapleleaf) approx. 2.5 mi N of 

site in the Oostanaula River 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.2 mi 

N of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.0 mi 

SE of site 

 GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.0 mi 

NE of site 

 GA Schisandra glabra (Bay Star-vine) approx. 1.7 mi SE of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi 

NW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.5 mi 

NW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi 

NW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 2.1 mi 

N of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi 

NW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 0.3 mi 

NW of site 

 US Scutellaria montana (Large-flowered Skullcap) approx. 1.3 mi 

NW of site 

 US Scutellaria montana (Large-flowered Skullcap) 

[EXTIRPATED] approx. 1.4 mi NW of site 

 Scutellaria nervosa (Bottomland Skullcap) approx. 0.5 mi NW 

of site 

 GA Silene regia (Royal Catchfly) [HISTORIC] approx. 1.3 mi NW 

of site 

 GA Symphyotrichum georgianum (Georgia Aster) approx. 1.3 mi 

NE of site 

 Tyto alba (Barn owl) in an uncertain location near the project 

site 

 Villosa umbrans (Coosa Creekshell) approx. 1.0 mi N of site in 

Two Run Creek 

 Villosa umbrans (Coosa Creekshell) approx. 2.8 mi N of site in 

an Unnamed Tributary to Oothkalooga Creek 

 Villosa umbrans (Coosa Creekshell) approx. 2.1 mi E of site in 

Dykes Creek 

 Villosa umbrans (Coosa Creekshell) approx. 1.8 mi NW of site 

in the Oostanaula River 

 US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 

1.8 mi E of site 

 Bartow County Greenspace approx. 2.6 mi N of site 

 Floyd County Greenspace approx. 2.6 mi W of site 

 Braden's Cave approx. 0.5 mi N of site 

 Celanese Cave approx. 1.7 mi W of site 

 Charles Floyd's Cave approx. 0.9 mi N of site 

 Jolley Cave approx. 0.8 mi N of site 

 Kingston Corner Cave approx. 1.9 mi N of site 
Atlanta

-Chattanooga HSGT Tier 1 DEIS 61 February 2017

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 Kingston Saltpeter Cave approx. 0.9 mi S of site 

 Lumpkin's Crawl [Cave], approx. 1.4 mi NW of site 

 Manis Cave approx. 1.6 mi SE of site 

 Mo Hole [Cave], approx. 2.6 mi SE of site 

 North Cat Den Cave approx. 2.0 mi SE of site 

 Plainville Cave approx. 0.5 mi NW of site 

 Quarles Bluff #1 [Cave], approx. 0.6 mi NW of site 

 Quarles Bluff #2 [Cave], approx. 0.5 mi NW of site 

 Self Cave approx. 0.9 mi S of site South Cat Den Cave 

approx. 2.0 mi SE of site 

 Yarbrough Cave approx. 2.4 mi SE of site 

 Oostanaula River 2 (0315010301) [SWAP High Priority 

Watershed] on site 

 Oothkalooga Creek (0315010302) [SWAP High Priority 

Watershed] on site 

 Armuchee Creek (0315010305) [SWAP High Priority

Watershed] approx. 2.0 mi NW of site 

 Allatoona Creek, Allatoona Lake (0315010409) [SWAP High 

Priority Watershed] approx. 2.0 mi SE of site 

 Pumpkinvine Creek (0315010411) [SWAP High Priority 

Watershed] approx. 2.4 mi S of site 

 Etowah River 3 (0315010413) [SWAP High Priority Watershed] 

on site 

 Etowah River 2 (0315010415) [SWAP High Priority Watershed] 

on site 

Recommendations: 

The Atlanta-Chattanooga High Speed Ground Transportation 

Project (PI: T001684) traverses many different habitat types. 

According to our records, several high priority species and 

communities have potential to be impacted by construction. We 

have included in this response a list of documented occurrences 

within three miles of the three proposed alternative routes. 

To minimize potential impacts to federally listed species, we 

recommend consultation with the United States Fish and Wildlife 

Service. In North Georgia, please contact Robin Goodloe (706-

613-9493, ext.221 or Robin_Goodloe@fws.gov). 

There are several state-protected species that have potential to be 

affected by the proposed construction. Please contact these 

biologists for recommendations/ assistance regarding the following 

taxonomic groups: 

Plants: Tom Patrick (Tom.Patrick@dnr.ga.gov); 

Fish & Crayfish: Brett Albanese (Brett.Albanese@dnr.ga.gov ); 

Mussels: Jason Wisniewski (Jason.Wisniewski@dnr.ga.gov ); 

Reptiles & Amphibians: John Jensen (John.Jensen@dnr.ga.gov ); 

Mammals: Trina Morris (Katrina.Morris@dnr.ga.gov); and
Atlanta

-Chattanooga HSGT Tier 1 DEIS 62 February 2017

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Birds: Nathan Klaus (Nathan.Klaus@dnr.state.ga.us). 

Once the preferred route has been established, our biologists can 

meet with project consultants to discuss survey needs for species 

of conservation concern and methods to minimize or mitigate 

impacts to these species. 

The proposed rail will transect several high priority watersheds 

identified in the State Wildlife Action Plan. Please refer to 

Appendix F of Georgia’s State Wildlife Action Plan to find out more 

specific information about these watersheds. 

(http://www.georgiawildlife.org/SWAP2015). 

South Cat Den Cave approx. 2.0 mi SE of site 

 Yarbrough Cave approx. 2.4 mi SE of site 

 Oostanaula River 2 (0315010301) [SWAP High Priority 

Watershed] on site 

 Oothkalooga Creek (0315010302) [SWAP High Priority 

Watershed] on site 

 Armuchee Creek (0315010305) [SWAP High Priority 

Watershed] approx. 2.0 mi NW of site 

 Allatoona Creek, Allatoona Lake (0315010409) [SWAP High 

Priority Watershed] approx. 2.0 mi SE of site 

 Pumpkinvine Creek (0315010411) [SWAP High Priority 

Watershed] approx. 2.4 mi S of site 

 Etowah River 3 (0315010413) [SWAP High Priority Watershed] 

on site 

 Etowah River 2 (0315010415) [SWAP High Priority Watershed] 

on site 

Disclaimer: 

Please keep in mind the limitations of our database. The data 

collected by the Nongame Conservation Section comes from a 

variety of sources, including museum and herbarium records, 

literature, and reports from individuals and organizations, as well 

as field surveys by our staff biologists. In most cases the 

information is not the result of a recent on-site survey by our staff. 

Many areas of Georgia have never been surveyed thoroughly. 

Therefore, the Nongame Conservation Section can only 

occasionally provide definitive information on the presence or 

absence of rare species on a given site. Our files are updated 

constantly as new information is received. Thus, information 

provided by our program represents the existing data in our files at 

the time of the request and should not be considered a final 

statement on the species or area under consideration. 
Atlanta-Chattanooga HSGT Tier 1 DEIS 63 February 2017

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If you know of populations of highest priority species that are not in 

our database, please fill out the appropriate data collection form 

and send it to our office. Forms can be obtained through our web 

site (http://www.georgiawildlife.com/node/1376) or by contacting 

our office. If I can be of further assistance, please let me know. 

Sincerely, 

 

Anna Yellin 

Environmental Review Coordinator 

 

Data Available on the Nongame Conservation Section Website 

Georgia protected plant and animal profiles are available on our 

website. These accounts cover basics like 

descriptions and life history, as well as threats, management 

recommendations and conservation status. 

Visit http://www.georgiawildlife.com/node/2721. 

Rare species and natural community information can be viewed by 

Quarter Quad, County and HUC8 

Watershed. To access this information, please visit our GA Rare 

Species and Natural Community 

Information page at: 

http://www.georgiawildlife.com/conservation/species-ofconcern?cat=conservation. 

Downloadable files of rare species and natural community data by 

quarter quad and county are also 

available. They can be downloaded from: 

http://www.georgiawildlife.com/node/1370.”
Atlanta-Chattanooga HSGT Tier 1 DEIS 64 February 2017

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Addressed in 

FEIS/ROD

42 John V. 

Edwards

Norfolk 

Southern

“Dear Ms. Heckler,

Norfolk Southern Railway Company (NS) certainly appreciates the 

opportunity to review and comment on the Tier 1 Draft 

Environmental Impact Statement ( "DEIS "), dated 

September2016, concerning the Atlanta - Chattanooga High 

Speed Ground Transportation Project. NS's comments are by 

necessity general, given the status of the DEIS.

Rail Technology. NS understands that the only passenger rail 

technologies being advanced for review are either Maglev or true 

high speed rail that is capable of speeds in excess of 180 mph and 

not compatible for operations on the same track as freight rail 

operations. DEIS at Section 0.1.3.2. See also DEIS at Section 

2.3.2 ( "All Corridor Alternatives would be exclusive facilities that do 

not share track with other trains and are grade separated when 

crossing roadways or rail lines.). All further comments below are 

made in reliance on this understanding. 

"Retained" Corridors. The DEIS has identified three NS corridors 

to be "retained," but at the same time the DEIS does not reflect any 

detailed analysis with regard to these three NS corridors. Instead, 

the DEIS states that any detailed analysis of these corridors would 

be "deferred to future studies as design options for the Atlanta 

area.” DEIS at Section 2.2. See also DEIS at Section 0.1.3.3 

(same). But the DEIS treatment of these corridors, including the 

so- called "NS Segment," DEIS at Section 2.1.2 (definition of NS 

Segment), Figures 2 -6 (inset), 2 -7, Figure 2-8, and Figure 2 -11, 

in no way "defers" consideration of these three options - the effect 

of "retaining" these NS corridors is to advance them for further 

consideration. In fact, the DEIS specifically states: Since the NS 

option would have virtually identical operational characteristics and 

potential environmental impacts as those following the I -75 

segment within the city of Atlanta (as shown in Table 2 -9), the 

Project Team has deferred the consideration of potential alignment 

configurations for the Downtown Atlanta Stations to the Tier 2 

NEPA phase. * * * Per NEPA and FRA guidance, the goal of this 

Tier 1 DEIS is to identify a corridor in which to implement the 

proposed service and to evaluate potential environmental impacts 

at a broad level. As such, folding those corridor alternatives 

following the NS segment with those following the 1 -75 segment 

during this Tier 1 DEIS would not preclude the potential 

consideration of alignments following the NS segmentin during 

future, Tier 2 NEPA analyses.

As such, and in the context of the DEIS, NS believes that there is 

no practical distinction between advancing these three corridor 

options for consideration under a Tier 2 NEPA analysis and the 

advancement of any other the other segments that are not 

identified as being retained put deferred. A portion of these three 

options are coextensive with the Southernmost I -75 Segment, to 

be discussed immediately below. A portion of these three options 

also include the so- called "NS Segment" which will be discussed 

separately. 

The NS areas of concern have been noted. Further coordination with 

transportation rights-of-way owners within the corridor, including the NS, 

would occur during subsequent phases of the HSGT Project. The exact 

location of HSGT alignments, station areas, ancillary facilties, and vehicle 

storage and maintenance facilties, as well as technology, vertical clearance,

and design options would be determined during subsequent phases of the 

HSGT Project. Evaluations for potential environmental impacts, including 

potential impacts to freight rail operations would be determined during Tier 2 

NEPA for the HSGT Project. 

Norfolk Southern 

Comment 11-18-2016

DEIS Errata ID 5

(Section 2.1.1)
Atlanta

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The Southernmost I -75 Segment. The I -75 Segments are

described as "generally follow[ing] the I -75 [right of way] from the 

area to the east of [Hartsfield Jackson Airport], known as the 

'Southern Crescent' located on the east side of [Hartsfield Jackson 

Airport], just east of I- 75, to the Tennessee border. Section 2.1.2 

(definition of I -75 Segment(s)). That description would seem to put 

the so- called "Southern Crescent" station in a triangular- shaped 

area bounded on the south by Interstate 285, on the west by 

Interstate 75, and on the east by NS.2 The HSGT route out of the 

Southern Crescent regional transit terminal would necessarily have 

to cross NS right of way either above -grade or under -grade 

because an at -grade crossing would not be acceptable.3 Careful 

engineering of either acceptable option would look to protecting 

clearances, stability of the right of way and facilities, expansion 

opportunities and, above all, safety. 

The southernmost 1 -75 Segment seems to follow the Interstate 75 

/Interstate 85 right of way until that right of way crosses over 

Interstate 20. At that point, it would appear from the Atlanta In -

Town Segments Inset portion of DEIS Figure 2 -6 that the 1 -75 

Segment heads due north, veering to the west of Interstate 75 to 

some undetermined location for a downtown Atlanta station. At this 

point, it appears as if the I -75 Segment would continue 

underground, but generally following the NS right of way, and not 

the Interstate 75 right of way, until it reaches Howell Junction. 

DEIS at Section 2.3.2, Figure 2.6 inset. 

Because the location of the proposed downtown Atlanta station is 

not known, it is impossible to discern whether the proposed above -ground portion of this segment or the proposed underground 

portion of this segment would cross the many intertwined NS and 

CSXtracks located in the so- called "Gulch" area, but a north /south 

I -75 Segment necessarily would cross those freight tracks either 

above -grade or under -grade. 

Further, as explained in our comments of July 7, 2010, NS does 

not permit within its right of way operations in excess of 90 mph. 

Therefore, to the extent the I -75 Segment seeks to be on the 

surface, it will necessarily have to be in a location outside of the NS

right of way. To the extent it is underground or above -ground, 

careful engineering would have to govern. Protection and 

preservation of all valuable subsurface and air rights would have to 

be integrated into any such plan. 

NS Segment. As detailed above, three alternatives that may be 

considered in a future Tier 2 NEPA analysis include the NS 

Segment, which appears to veer off from the 1 -75 segment in the 

area of Howell Junction, following the NS right of way to a point of 

intersection with Interstate 285. It is not clear from the DEIS 

whether the route would be via a tunnel or not. To the extent the 

NS Segment seeks to be on the surface, it will necessarily have to 

be in a location outside of the NS right of way. To the extent it is 

underground or above -ground, the same level of careful 

engineering and rights protections would have to govern. 
Atlanta-Chattanooga HSGT Tier 1 DEIS 66 February 2017

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Downtown Chattanooga. NS recognizes that each of the three 

alternatives being progressed (the I -75 Corridor, the East Corridor, 

and the I -75 /Rome Corridor alternatives) appear to be the same 

between the Chattanooga Airport and downtown Chattanooga, 

which specificallyis a route "following an existing CSX rail line [right 

of way]." DEIS at Section 2.1.2 (definition of the Downtown 

Chattanooga Segment). NS makes no comment with regard to a 

routing through Chattanooga along the CSX right of way.

Sincerely, John V. Edwards”

43 Daniel F. 

Wallace

USDA NRCS 

Georgia 

Resource 

Inventory

Coordinator

“Hello, I am preparing a respond from NRCS to the Oct. 21 

notification of the Tier 1 Draft EIS. One of NRCS’s statutory 

responsibilities is the Farmland Protection Policy Act (FPPA). I 

have prepared some responses to the HSGT over the years that 

pointed out the necessity of this project going through the FPPA 

process. I don’t see anything in the draft EIS addressing FPPA. 

But it’s a very big document. Are you familiar with the details, and, 

if so, do you know of sections of the EIS addressing FPPA? The 

act is an effort to stop federal funds irreversibly converting the 

nation’s farmland out of farmable use. It relies on identifying soils 

rated as prime farmland and assessing for the least converting 

alternative.

 

It’s no big deal if it’s not there, I’ll just prepare the response pointing 

out that FPPA consultation is necessary. But, if it’s there, I’d like to 

prepare the response accordingly. Thank you, Dan.”

The Tier 1DEIS does not address the Farmland Protecion Policy Act (FFPA). 

The FEIS/ROD will address potential impacts to farmland within the Build 

Alterative Corridors and will address requirements under the Farmland 

Protection Policy Act.

NRCS Comment 11-

16-2016

Section 2.4.3 of 

the Record of 

Decision

44 Kendra 

Abkowitz, 

PhD

Tennessee 

Department of 

Environment 

and 

Conservation

Dear Ms. Heckler:

The Tennessee Department of Environment and Conservation 

(TDEC) appreciates the opportunity to provide comments on the 

Federal Railroad Administration (FRA), Georgia Department of 

Transportation (GDOT), and Tennessee Department of 

Transportation (TDOT) Atlanta-Chattanooga High Speed Ground 

Transportation Project Tier I Draft Environmental Impact Statement 

(Draft EIS). The FRA, in cooperation with GDOT and TDOT, 

proposes to construct a high-speed intercity passenger service 

connecting Atlanta, Georgia and Chattanooga, Tennessee. The 

project aims to enhance intercity mobility and economic growth 

throughout the project area between the metropolitan areas and 

Concurrence and/or no further comment has been noted for the following 

TDEC departmnets:

 Tennessee Geological Survey

 Tennessee State Parks and Real Property Manamgenet

 Division of Archaeology

Further coordination with local, State, and Federal resource agencies, 

including the Tennessee Department of Environment and Conservation, 

would occur during subsequent phases of the HSGT Project. Information on 

Section 408 and coordination that would be required for impacts to 

streams/open waters will be added to the FEIS.The resources of concern 

and proposed best management practices and mitigation and avoidance 

TDEC Comments 11-

18-2016

DEIS Errata ID 

18 (Section 

3.9.6)
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the airports of Atlanta and Chattanooga by providing faster and 

more reliable ground transportation service to the public as an 

alternative to highway, intercity bus, and air travel in a manner that 

is safe and cost-effective, while avoiding, minimizing, and 

mitigating impacts on the human and natural environment.

Actions considered in detail within the Draft EIS include:

· No-Build Alternative – Under the No-Build Alternative, the FRA, 

GDOT, and TDOT would take no action to construct a high-speed 

ground transportation (HSGT) project in the project area. Existing 

transportation systems would remain in place, and all 

transportation system improvements that are currently listed in 

local, regional, and state transportation plans that have identified 

funds for implementation will be implemented.

· I-75 Corridor Alternative – Under the I-75 Corridor Alternative, the 

HSGT project would begin on the east side of Hartsfield-Jackson 

Atlanta International Airport immediately adjacent to I-75, following 

I-75 north along the I-75 right-of-way (ROW). North of I-24 in 

Tennessee, the corridor continues along an existing CSX rail ROW 

to downtown Chattanooga.

· East Corridor Alternative – Under the East Corridor Alternative, 

the HSGT project would follow the same alignment as the I-75 

corridor until Cartersville, where it would deviate from I-75 and 

continue along existing CSX ROW parallel to US 411 and into 

Chattanooga.

· I-75/East Corridor Alternative – Under the I-75/East Corridor 

Alternative, the HSGT project would follow the same path as the I75 and East corridors to Cartersville and follow US 411 to Rome, 

where it would

continue along an existing CSX ROW to rejoin I-75 between 

Cartersville and Dalton. The corridor would continue along the I-75 

ROW to Dalton and into downtown Chattanooga. TDEC’s Office of 

Energy Programs and the Tennessee Geological Survey (TGS) 

have reviewed the Draft EIS and have no specific comments 

regarding the proposed action or its alternatives.

TDEC’s Tennessee State Parks and Real Property Management 

have reviewed the Draft EIS and note that the proposed project 

should not impact TDEC managed lands.

TDEC’s Division of Archaeology (DoA) has reviewed the Draft EIS 

and provides the following comments regarding the proposed 

action alternatives that occur within Tennessee. TDOT 

archaeologists have identified all properties in the study area that 

are listed or potentially eligible for listing in the National Register of 

Historic Places (3.8.4.2). DoA notes that other potentially 

significant sites may exist and have yet to be identified, which will 

be determined by TDOT as part of their responsibilities to comply 

with Section 106 (3.8.6). At this time, DoA concurs with TDOT 

findings and suggestions related to this project as discussed within 

the Draft EIS.

TDEC’s Division of Natural Areas (DNA) has reviewed the Draft 

EIS and provides the following comments regarding the proposed 

activities outlined in the response letter dated November 18, 2016 would be 

considered a starting point for further discussion and potential analysis within 

any planning, environmental, and conceptual design work performed during 

subsequent phases of the HSGT Project. The resources and concerns 

noted in the letter also provide the Federal Railroad Administration (FRA), the 

Georgia Department of Transportation (GDOT), and the Tennessee 

Department of Transportation (TDOT) with awareness of particular issues 

within the corridors that may be useful for planning activities for other 

transportation projects that may fall within the parameters of the three Build 

Alternative Corridors that were evaluated in the DEIS. The discussion under 

the Air Quality section of the FEIS will be expanded from what is included in 

the DEIS and additional information concerning the air quality conformity 

determination deferment to Tier 2 NEPA analysis will be provided. A 

disclosure of expected data needed for this determination will also be 

provided in this section.
Atlanta

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action alternatives that occur within Tennessee. For areas of the 

project occurring in Hamilton County, Tennessee, DNA prefers for 

the project to use an existing corridor when possible. Besides the 

known occurrences of rare species included in the NEPA 

document for Hamilton County, there could be additional rare 

species that DNA is unaware of because not all of Tennessee has 

been surveyed. Should suitable habitat for rare species existing 

on or immediately downstream of the project site, DNA 

recommends that the project plans provide for the protection of 

these species. For stabilization of disturbed areas, the Tennessee 

Natural Heritage Program advocates the use of native trees, 

shrubs, and warm season grasses, where practicable. Care 

should be taken to prevent re-vegetation of disturbed areas with 

plants listed by the Tennessee Exotic Pest Plan Council as harmful 

exotic plants. TDEC’s Division of Air Pollution Control (APC) has 

reviewed the Draft EIS and provides the following comments 

regarding the proposed action alternatives that occur within 

Tennessee.

· Dust emissions generated by construction activities can vary 

substantially depending on levels of activity, specific operations, 

and prevailing meteorological conditions. However, dust 

emissions due to construction activities are likely to be short-term 

and temporary in nature. It is recommended that ordinary dust 

control measures, such as wetting by water spray, be employed to 

mitigate any dust emissions generated. APC recommends that 

mitigation of dust emissions be addressed in future National 

Environmental Policy Act (NEPA) documents related to this 

project.

· Exhaust emissions generated by onsite construction equipment 

are not likely to be of concern during the project. However, APC 

recommends that mitigation of exhaust emissions be addressed in 

future NEPA documents related to this project.

· The proposed project does not reference demolition of buildings. 

However, if demolition is to occur, fugitive dust emissions 

produced may require mitigation. Demolition would also require an 

asbestos demolition notification in advance of any activity as well 

as proper pre-demolition surveys to identify any regulated 

asbestos-containing materials (ACM) that may be present. Should 

any ACM be present, it would need to be handled and disposed of 

according to applicable Federal, state, and local regulations. This 

should be addressed in future NEPA documents.

· Should any land clearing activities or disposal of brush or 

trees/tree limbs occur, APC prefers that wood waste be disposed 

of by chipping, grinding, or composting rather than open burning. 

However, if open burning does occur during site preparation and 

construction, open burning regulations should be followed. APC 

recommends that detailed clearing activities, total amount of areas 

where soils are to be disturbed, and associated impacts be 

addressed in future NEPA documents related to this project.

· The National Ambient Air Quality Standards (NAAQS) table 
Atlanta

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(Table 3.6) provided does not include the revised ozone standard 

of 0.070 ppm.3

· Page 3-20 indicates that TDEC APC is responsible for monitoring 

and enforcing air quality regulations in the State of Tennessee. While this statement is correct, in the case of Hamilton County, the 

Chattanooga/Hamilton County Air Pollution Control Bureau has 

been delegated authority to monitor air quality and has jurisdiction 

over air quality issues within the county. This should be reflected 

in future NEPA documents related to this project.

· Page 3-21 of the Draft EIS notes that Chattanooga is classified 

as a Non-Attainment Area for the 1997 PM2.5 Annual Standard. 

Chattanooga is actually classified as attaining the 1997 2.5 Annual

Standard. It is recommended that this be reflected in future NEPA 

documents related to this project.

· Data contained within Table 3-7 for Hamilton County should be 

updated to reflect the 2014, 2015, and possibly 2016 data for 

Chattanooga rather than 2012 and 2013 data. TDEC’s Division of 

Water Resources (DWR) has reviewed the Draft EIS and provides 

the following comments regarding the proposed action alternatives 

that occur within Tennessee. As is typical with long range 

transportation planning and project execution, specific project 

details associated with each alternative are still being determined. 

DWR looks forward to working with TDOT, GDOT, and FRA as 

this project develops.

· The Tennessee portion of the project will likely required an 

Aquatic Resource Alteration Permit for stream crossings, wetlands, 

etc., as well as a construction stormwater permit due to the large 

area being disturbed exceeding one acre.

· Construction activities, including clearing, grading, filling, and 

excavating, or other similar activities, including staging areas, that 

result in the disturbance of one acre or more of total land area 

require coverage under Tennessee’s General National Pollutant 

Discharge Elimination System (NPDES) permit for discharges of 

stormwater associated with construction activities.

· Given the karst geology of the area, a letter of authorization from 

DWR’s Underground Injection Control program for sinkhole 

modification will likely be required as well.

TDEC appreciates the opportunity to comment on this Draft EIS. 

Please note that these comments are not indicative of approval or 

disapproval of the proposed action or its alternatives, nor should 

they be interpreted as an indication regarding future permitting 

decisions by TDEC. Please contact me should you have any 

questions regarding these comments.

Sincerely, Kendra Abkowitz, PhD.” 
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45 Steve Allen Tennessee 

Department of 

Transportation

“Ariel 

In the TIER 1 DRAFT ENVIRONMENTAL IMPACT STATEMENT, 

you need to change the point of contact as David Utley has not 

been the project manager for a very long time. I have included the 

correct contact information. 

David Utley, Project Manager 

Strategic Transportation Investments Division Tennessee 

Department of Transportation 

505 Deaderick Street. Suite 1000 

Nashville, TN 37243 

(615) 253-2422 

Needs to be changed to: 

Liza M. Joffrion | Director 

Division of Multimodal Transportation Resources 

James K. Polk Building, 18th Floor 

505 Deaderick Street, Nashville, TN 37243 

p. 615-741-2781 

liza.joffrion@tn.gov 

tn.gov/tdot 

Thanks 

Steve”

Point of contact for the Tennessee Department of Transportation has been 

updated from David Utley to Liza Joffrion.

TDOT - Change PM 

Contact Information for 

FEIS 11-4-2016

46 E. Patrick 

McIntyre, 

Jr.

Tennessee 

Historical 

Commission

“Dear Ms. Heckler: 

In response to your request, we have reviewed the Tier 1 DEIS 

submitted regarding your proposed undertaking. Our review of 

and comment on your proposed undertaking are among the 

requirements of Section 106 of the National Historic Preservation 

Act. This Act requires federal agencies or applicants for federal 

assistance to consult with the appropriate State Historic 

Preservation Office before they carry out their proposed 

undertaking. The Advisory Council on Historic Preservation has 

codified procedure for carrying out Section 106 review in 36 CFR 

800 (Federal Register, December 12, 2000, 77698-77739). 

Upon receipt of additional detailed Section 106 consultation 

documentation, we continue our review of this undertaking 

expeditiously as possible. 

Until such time as this office has rendered a final comment on this 

project, your Section 106 obligation under federal law has not been 

met. Please inform this office if this project is canceled or not 

funded, permitted, or licensed by the federal agency. Questions 

and comments may be directed to Jennifer M. Barnett (615) 741-

1588, ext. 105. Your cooperation is appreciated. Sincerely. E. 

Patrick McIntyre”

FRA, GDOT, and TDOT will meet the obligations for Section 106 

consultation at a later stage of the HSGT Project. As requested, FRA, 

GDOT, and TDOT will notify the Tennessee Historical Commission should 

the Project be cancelled, not funded, permitted, or licensed by the federal 

agency.

TN Historical 

Commission 

Comments 11-10-2016
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47 Holly 

Austin

Tribal Historical 

Preservation 

Office

“Ms. Heckler:

The Tribal Historic Preservation Office of the Eastern Band of 

Cherokee Indians (EBCI THPO) accepts the invitation to comment 

on this proposed Section 106 activity under §36CFR800.

It is the opinion of the EBCI THPO that no cultural resources 

important to the Cherokee people should be adversely impacted 

by this proposed federal undertaking, or any of the proposed 

alternatives. The I-75 Corridor Alternative that is the preferred 

alternative is perfectly acceptable to this office. As such, this

proposed undertaking may proceed as planned. In the event that 

project design plans change, or cultural resources or human 

remains are inadvertently discovered during site prep and 

construction phase, the EBCI THPO requests that all work cease 

and be notified so we may continue the nation-to-nation 

consultation process as stipulated under §36CFR800. 

If we can be of further service, or if you have any comments or 

questions, please feel free to contact me at (828) 359-6854. 

Sincerely, Holly Austin.”

Preference towards the I-75 Corridor Alternative has been noted. FRA, 

GDOT, and TDOT look forward to working with the EBCI THPO during 

subsequent phases of work on the HSGT Project.

Tribe - Eastern Band of 

Cherokee Indians - 11-

14-2016

48 Karen 

Pritchett

Tribal Historical 

Preservation 

Office

“Dear GDOT, 

On behalf of Tribal Historic Preservation Officer (THPO) Eric 

Oosahwee-Voss, please accept this digital communication 

regarding the Tier 1 DEIS for the Atlanta to Chattanooga High 

Speed Ground Transportation Project. 

Please be advised that the proposed undertaking lies within the 

traditional territory of the United Keetoowah Band of Cherokee 

Indians in Oklahoma (UKB). This opinion is being provided by UKB 

THPO, pursuant to authority vested by the UKB Corporate Board 

and under resolution 16-UKB-34. The United Keetoowah Band is a 

Federally Recognized Indian Nation headquartered in Tahlequah, 

OK. 

Our preferred alternative is the I-75 corridor, however, please note 

that whatever corridor is chosen, we want a full cultural resources 

study prior to project implementation. Thank you for consulting 

with the UKB. Please note that these comments are based on 

information available to us at the time of the project review. We 

reserve the right to revise our comments as information becomes 

available. If you have any questions or concerns, please contact 

me at (918) 458-6715 or kpritchett@ukb-nsn.gov or THPO Eric 

Oosahwee-Voss at (918) 458-6717 or eoosahwee-voss@ukbnsn.gov 

UKB# U16-945 

16.0973 

Thank you, 

Karen Pritchett.”

Preference towards the I-75 Corridor Alternative has been noted. FRA, 

GDOT, and TDOT look forward to working with the United Keetoowah Band 

of Cherokee Indians in Oklahoma (UKB) during subsequent phases of work 

on the HSGT Project. Additional planning and environmental work during 

subsequent phases of the HSGT Project would fully address all obligations 

under Section 106 of the National Historic Preservation Act. A 

comprehensive cultural resources study would occur with Tier 2 NEPA 

during subsequent phases of the HSGT Project.

Tribe - United 

Keetoowah Band of 

Cherokee Indians 

Comment - 11-21-2016
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49 Donald W. 

Imm, PhD

United States 

Department of 

the Interior,

Fish and 

Wildlife Service

Dear Mr. Winkle:

Please accept the following comments on the Tier 1 Draft 

Environmental Impact Statement for the proposed AtlantaChattanooga High Speed Ground Transportation Project (GDOT 

PI: T001684) dated September 2016, on behalf of Georgia 

Ecological Service, U.S. Fish and Wildlife Service. Please note for 

your files that Carrie Straight will be serving as Georgia Ecological 

Services’ contact for any future NEPA-related studies.

Coordination History with Georgia Ecological Services:

August 22, 2007. A Notice of Intent was published in the Federal 

Register (Vol. 72, No. 162, Pages: 47121-

47122). That the FHWA and FRA will be jointly preparing an 

Environmental Impact Statement with

GDOT and TDOT on the impacts related to the proposed project.

August 23, 2007. The Service received a notice from the Assistant 

Director Fisheries and Habitat Conservationregarding a Notice of 

Intent for a 110-Mile High-Speed Ground Transportation Corridor 

from Atlanta

to Chattanooga. The Service notified our Regional Office on 

September 10, 2007, that we would work

with GDOT to assess the Service’s concerns related to the project.

March 28, 2008. The Service received a letter from GDOT dated 

March 14, 2008, requesting the Service to

become a participating agency in coordination with the FRA, 

FHWA, and GDOT.

August 27, 2008. The Service received a letter from GDOT which 

acknowledged the Service’s participation in the planning process 

and included a list of contacts of other organizations/agencies 

involved in the

project planning.

June 14, 2010. The Service received a letter from GDOT dated 

June 10, 2010, containing a Revised

Coordination Plan Version (2.0): May 2010.

July 26, 2010. The Service sent a letter to GDOT, accepting the 

role as a participating agency in the project

planning process.

August 5, 2010. The Service received a letter from GDOT dated 

August 2, 2010, containing a list of the

participating agencies for the project’s National Environmental 

Policy Act (NEPA) planning process.

September 8, 2010. The Service received an early coordination 

letter from GDOT dated September 3, 2010.

September 13, 2010. The Service received a letter from GDOT 

dated September 10, 2010, requesting the

Service’s participating in a screening meeting to be held on 

September 23, 2010.

October 19, 2010. The Service participated in a meeting focused 

on introducing the project to participating

agencies.

November 19, 2010. The Service submitted a letter to GDOT in 

Point of contact for the Georgia Ecological Services has been updated to 

Carrie Straight.

Further coordination with local, State, and Federal resource agencies, 

including those under the U.S. Department of the Interior, United States Fish 

and Wildlife Service (USWFS), would occur during subsequent phases of the 

HSGT Project. The USWFS’s resources of concern and proposed best 

management practices and mitigation and avoidance activities outlined in the 

response letter dated November 21, 2016 would be considered a starting 

point for further discussion and potential analysis within any planning, 

environmental, and conceptual design work performed during subsequent 

phases of the HSGT Project. The resources and concerns noted in the letter 

also provide the Georgia Department of Transportation and the FRA with 

awareness of particular issues within the corridors that may be useful for 

planning activities for other transportation projects that may fall within the 

parameters of the three Build Alternative Corridors that were evaluated in the 

DEIS.

The FWHA is no longer a co-lead Federal agency. The FHWA requested a 

change in role from co-lead Federal agency to participating letter in a letter 

dated July 15, 2014. The FRA agreed to this request. 

USFWS Comments 11-

3-2016

DEIS Errata ID 

14 (Section 

3.7.6)

DEIS Errata ID 

22 (Section 

3.10.5)

DEIS Errata ID 

23 (Section 

3.10.6)
Atlanta

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response to their early coordination request,

listing endangered and threatened species concerns related to the 

proposed project alignments. The

Service requested that avoidance and minimization options be 

enacted for those listed species along the

project corridor. The Service also requested several specific items 

related to reducing impacts to listed

species: 1) GDOT consider clear-spanning any crossings of 

sensitive waters (in areas of designated

critical habitat and where listed aquatics occur), 2) stormwater 

measures be enacted in the Etowah

River system, and 3) the population of Tennessee Yellow-eyed 

Grass be avoided where it occurs near

the US 411 / I-75 interchange

July 15, 2014. The Service received a letter from FHWA to FRA 

dated July 15, 2014, rescinding their role as a co-lead agency and 

changed to a participating agency.

October 13, 2016. The Georgia Ecological Field Office, Athens, 

GA, received notification from the Assistant

Director of Ecological Services request for comments on the Draft 

Tier I Environmental Impact

Statement. The last coordination for the proposed project occurred 

with our office in September 2010. Since that coordination, there

have been several new species listed and species previously listed 

have had their ranges expanded in Georgia. We would request an 

updated ArcGIS shapefile/layer or similar product of the 1,000-foot 

width of each of the three alignments discussed in the draft EIS.

The Service received a 2014 letter from Georgia Division of FHWA 

rescinding their role as a co-lead for this project. Is FHWA still a co-

lead agency? If not, please update any reference to FHWA as a 

co-lead federal agency in the final EIS and any appendices where 

appropriate.

Protected Lands (Section 3.7). Each of these alignments has the 

potential to impact protected conservation lands that appear to 

have not been included in your analysis and could include 

conservation easements, conservation banks, and mitigation sites. 

Please be aware the sites should be avoided if possible and any 

impacts to these sites (as with other federal lands including Forest 

Service, Park Service) would have a higher mitigation ratio than 

typical impacts to nonprotected lands to offset the impacts to these 

lands designated as protected for natural resources. In Section 

3.7.5 [Potential Mitigation], please note that the cost of mitigating 

these impacts, if a monetary mitigation is chosen will be higher 

than typical ratios of unprotected lands.

Water Resources (Section 3.9). Please be aware that each of the 

three alignments cross through sensitive waters in some portions 

of the Upper Coosa (Etowah, Oostanaula, Coosawattee, and 

Conasauga). There are designated critical habitats for listed 

aquatics in portions of the rivers that will have either direct or 

indirect impacts by the project. Also, there are portions of each 
Atlanta

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alignment that travel through watersheds identified as high priority 

during the 2015 revision of Georgia’s State Wildlife Action Plan. 

These watersheds were identified as high priority based on the 

number of high priority aquatic species populations present in the 

watershed and the rarity of those species. There are also rivers in 

theregion that are cold water and listed as trout streams. These 

sensitive water resources host listed or at-risk aquatic as well as a 

food-base for listed bats within the area. In areas where there will 

be increases of impervious surfaces (including rail lines, storage, 

maintenance, inspection facilities, stations, parking, new 

connecting roadways, and improvements to existing roadways), 

we request that the project developers consider efforts to 

ameliorate the effects of

stormwater runoff and impacts to water temperature to any 

receiving waters. Please consult our office under provisions of the 

Fish and Wildlife Coordination Act regarding any permanent or

temporary impacts related to the project construction as well as 

post-construction impacts to water resources. This would include 

construction activities using temporary work bridges, jetties, bank 

armoring or reinforcement, and erosion

and sedimentation concerns. Because of karst geology and cave 

habitats along each of the alignments, please determine what 

geotechnical assessments are needed to ensure that the project 

would not pollute groundwater through natural fissures or during 

blasting/drilling activities.

Biological Resources (Section 3.10).

Comments specific to Table 3-25: I am unsure how this table is 

organized, but listing species by scientific name within each taxon 

group might be the easiest for those familiar with the species to 

assess the list for missing or inaccurate information. Does the 

State status listed in the Table refer to Georgia or Tennessee or 

both? Please clarify this information. Please cross-check the state 

listings for Georgia, several appear to be missing or inaccurate.

Northern Long-eared Bat is now listed as Threatened. Also, the 

range should be updated to include all counties within the project 

alignment (including Tennessee).

Rafineque's Big-eared Bat could occur along all three alignments. 

The range for this species is expected in the Blue Ridge, Ridge 

and Valley, and Southwestern Appalachians.

Red-cockaded Woodpecker does have a historical range in the 

northwestern part of Georgia; however, the species no longer 

occurs in this region and would not be of concern for any of the 

alignments.

In the table the scientific name for Freckled Darter is misspelled. 

Please correct to read Percina lenticula.

Both Monkeyface Orchid (Threatened) and Georgia Rockcress 

(Threatened) are now listed species. Please update the table to 

reflect that information. Please note that White Fringeless Orchid 

and Monkeyface Orchid are the same species (Platanthera 

integrilabia), with differing common names used by each state. 
Atlanta

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Additionally please note that Michaux’s Sumac and Dwarf Sumac 

are the same species (Rhus michauxii). Please combine each of 

these into single rows. Additional Comments related to Section 

3.10:

Please be aware that there are over 100 species that are currently 

petitioned under the Endangered Species Act that occur or have 

occurred in Georgia. There are several species that have the 

potential to occur within the project corridor and could be listed 

before the project or project design will be completed. Our office 

will attempt to make recommendations, as early as possible, to 

minimize impacts and be protective of these species during our 

consultation with GDOT.

The Etowah HCP (http://etowahaquatichcp.org/), although not 

formally adopted by the Service as a Habitat Conservation Plan, 

gives guidance for the protection of water quality and listed 

aquatics within the Etowah River watershed. Please use these 

guides for stormwater protections within the Etowah and in areas 

draining to critical habitats for listed aquatics. Specifically assess 

Section 4 of the following report, which gives guidance for post-

development stormwater

management 

(http://www.etowahaquatichcp.org/research/documents/tech_rpt_s

tormwater_8_20_07.pdf).

In Section 3.10.5, the start of the second paragraph states 

potential mitigation strategies include... These efforts would be

defined by the Service as minimization efforts (i.e. to minimize the 

impact to listed species and their habitats). For unavoidable 

impacts to listed species and their habitats, we would request that 

FRA consider requiring conservation banking and in-lieu fee 

mitigation. Conservation credits are currently available for impacts 

to Cherokee Darters at the Deerleap Conservation Preserve. 

Please consider in-lieu fee or in-kind mitigation for other aquatics 

and bats. There is a mechanism in place to accept in-lieu 

mitigation with The Conservation Fund for impacts to bat habitat 

and with The Nature Conservancy for impacts to aquatics.

Although the Draft EIS states that a large portion of each corridor 

alternative will occur within the existing right-of-way, there are 

occurrences of listed species within the existing right-of-way of I-

75. We have records of critical habitat within and along both the 

Rome/I-75 and the East Corridors. These habitats should be 

avoided.

If your project will directly or indirectly affect hardwood forests, 

please conduct vegetation surveys to determine the level of 

consultation necessary with our agency, in addition to developing 

appropriate avoidance, minimization, and mitigation measures, if 

appropriate. If the project will directly or indirectly affect caves or 

other cave-like structures, please contact our office to assess 

impacts to these resources as maternity roost for Gray Bats or 

hibernacula for Northern Long-eared Bats and other at-risk bat 

species. All of the listed bats and other at-risk bat species have 
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been documented using man-made structures as roosts. Please 

complete inspections of all bridges, culverts, and structures that 

could be impacted by the project to determine if the structure is 

being utilized as a roost by bats. In addition, in sensitive areas, 

vibrations or blasting from construction activities could impact 

protected bats and nearby roosts. Please assess the trade-offs of 

using traditional and alternative construction methods and time of 

day restrictions for driving piles and other activities with high noise 

or vibrations.As the proposed project design is developed, please 

consider assessing design measures to minimize impacts to

terrestrial wildlife for the at-grade portions of the proposed 

alignments and birds and bats for all alignments, especially along 

commonly used flight paths and movement/migration corridors. It 

would be beneficial to conduct an analysis of potential mortality 

and fragmentation of habitat for species of concern.

Because a purpose of the proposed project is to enhance 

economic growth throughout the Project Area, please consider

additional analyses for the Tier 2 NEPA or once the preferred 

alternative is selected (Section 3. 11 ). Please assess the project's 

impacts to listed species related to interrelated and interdependent 

actions. This should include any predictions or inclusions of the 

proposed project in state, county, municipal, or city planning 

documents for development along the proposed project alignment. 

This assessment should catalog likely changes in habitat or 

impervious surface in those areas relative to the baseline 

conditions. If the project is expected to require the relocation of 

utility lines, other service lines, or existing facilities, please include 

the impacts ( direct and indirect) on the listed species as a result of 

those impacts.

If you have any questions or require further information, please 

contact staff biologist Carrie Straight, at 706-61 3-9493,

ext. 227.

Sincerely,

Donald W. Imm, PhD.
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 4

Atlanta-Chattanooga HSGT Tier 1 DEIS 124 February 2017

ATLANTA-CHATTANOOGA

HIGH SPEED GROUND TRANSPORTATION PROJECT

TIER 1 DEIS PUBLIC AND AGENCY 

INVOLVEMENT SUMMARY REPORT

ATTACHMENT 4: CORRESPONDENCE 

RECEIVED DURING TIER 1 DEIS REVIEW 

PERIOD

Prepared by:

Federal Railroad Administration (FRA)

Georgia Department of Transportation (GDOT)

Tennessee Department of Transportation (TDOT)

February 2017
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 4

Atlanta-Chattanooga HSGT Tier 1 DEIS 125 February 2017
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 4

Atlanta-Chattanooga HSGT Tier 1 DEIS 126 February 2017
Tier 1 DEIS Public and Agency Involvement Summary Report

Attachment 4

Atlanta-Chattanooga HSGT Tier 1 DEIS 127 February 2017
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APPENDIX C: 

AGENCY CORRESPONDENCE 

RECEIVED
APPENDIX C: 

AGENCY CORRESPONDENCE 

RECEIVED
A D V ANCIN G GREAT PLACE S

 

Chattanooga-Hamilton County 

Regional Planning Agency 

Chattanooga-Hamilton County/ 

North Georgia 

Transportation Planning 

Organization 

1250 Market Street, Suite 2000 

Chattanooga, TN 37402 

www.chcrpa.org 

(423) 757-5216

November 9, 2016

Commissioner

Georgia Department of Transportation

Dear Commissioner:

The Chattanooga‐Hamilton County/North Georgia Transportation Planning Organization’s active

2040 Regional Transportation Plan calls attention to the Atlanta to Chattanooga High Speed Rail

project addressing the following milestone accomplishments and status:

 A Tier I Environmental Assessment (EA) has been completed;  

 A Tier II Environmental Impact Statement (EIS) for this segment is currently underway

by Georgia; and  

 High Priority Project funds were also obligated in the CHCNGA’s TPO’s FY 2011‐2014

TIP for a feasibility study of the Chattanooga to Nashville segment.  

The 2040 plan further supports this project by suggesting the project would expand opportunity

for existing and future connections to converge at the Chattanooga Metropolitan Airport,

adding to the pressure to provide better transit service and providing opportunity to make this

a mobility hub. However, the plan notes:  

“Federal funding has been appropriated, though not yet authorized, for the continuation of

project development for the Atlanta‐Chattanooga‐Nashville high speed rail corridor. It is

anticipated that these funds will be released in the near future.

Funding for implementation of the project is expected to come from various sources including,

but not limited to Federal Rail Administration, Federal Highway Administration, and Federal

Transit Administration as well as state and local partners.

Funding for this project will be included in a future RTP update given the status of the

appropriations and likelihood the project will move forward in the future.”

Staff of the TPO continues to provide support and assist in planning functions association with

seeing this project develop and supports the I‐75 alignment for its reduced environmental

impacts and high performance in the cost/benefit analysis.  TPO staff also plans to attend the

upcoming public meetings and looks forward to considering the project in the TPO’s upcoming

2045 RTP expected for completion in 2018.

Sincerely,

Melissa Taylor

Director, Strategic Long Range Planning

Chattanooga‐Hamilton County Regional Planning Agency &

Chattanooga‐Hamilton County/North Georgia Transportation Planning Organization

DATE: 14 – November – 16 

TO: Georgia Department of Transportation

Division of Intermodal

ATTN: Ariel Heckler, Project Manager

One Georgia Center

600 West Peachtree Street NW

Atlanta, GA 30308

 

PROJECT: Atlanta-Chattanooga High Speed Ground Transportation Project.

Ms. Heckler:

The Tribal Historic Preservation Office of the Eastern Band of Cherokee Indians (EBCI THPO) 

accepts the invitation to comment on this proposed section 106 activity under §36CFR800.

It is the opinion of the EBCI THPO that no cultural resources important to the Cherokee people 

should be adversely impacted by this proposed federal undertaking, or any of the proposed 

alternatives. The I-75 Corridor Alternative that is the preferred alternative is perfectly acceptable 

to this office. As such, this proposed undertaking may proceed as planned. In the event that 

project design plans change, or cultural resources or human remains are inadvertently discovered

during site prep and construction phase, the EBCI THPO requests that all work cease and be 

notified so we may continue the nation-to-nation consultation process as stipulated under 

§36CFR800. 

If we can be of further service, or if you have any comments or questions, please feel free to 

contact me at (828) 359-6854.

Sincerely,

Holly Austin

Tribal Historical Preservation Office

Eastern Band of Cherokee Indians

Eastern Band of Cherokee Indians

Tribal Historic Preservation Office

P.O. Box 455

Cherokee, NC 28719

Ph: 828-359-6854 Fax 828-488-2462


MARK WILLIAMS RUSTY GARRISON

COMMISSIONER DIRECTOR

NONGAME CONSERVATION SECTION

2065 U.S. HIGHWAY 278 S.E. | SOCIAL CIRCLE, GEORGIA 30025-4743

770.918.6411 | FAX 706-557-3580| WWW.GEORGIAWILDLIFE.COM

November 22, 2016

Ariel Heckler

Rail Planner

Georgia Department of Transportation

600 W Peachtree Street NW

Atlanta, GA 30308

Subject: Known occurrences of natural communities, plants and animals of highest priority 

conservation status on or near Atlanta to Chattanooga HSGT Project, Multiple Counties, 

Georgia

Dear Ms. Heckler:

The Georgia Department of Natural Resources appreciates the opportunity to provide comments 

on the Draft Environmental Impact Statement for this project. This is in response to the 

information we received October 31, 2016. The following species and natural communities of 

conservation concern and conservation lands are known within the project area:

Atlanta Hartsfield Jackson International Airport to southernmost split of Alternatives

GA Ammodramus henslowii (Henslow's Sparrow) approx. 0.5 mi NE of site 

Asplenium bradleyi (Bradley's Spleenwort) [HISTORIC] approx. 0.9 mi SW of site 

Boechera missouriensis (Missouri Rockcress) approx. 2.2 mi SW of site 

Buchnera americana (Bluehearts) [HISTORIC] in an uncertain location near the project 

site

Calystegia catesbeiana ssp. sericata (Silky Bindweed) approx. 1.5 mi SW of site 

GA Cambarus howardi (Chattahoochee Crayfish) approx. 0.3 mi SW of site in the 

Chattahoochee River

GA Cambarus howardi (Chattahoochee Crayfish) approx. 2.9 mi NE of site in Sope Creek

GA Cambarus howardi (Chattahoochee Crayfish) in an uncertain location near the project site 

in Rottenwood/ Poplar Creek

GA Cambarus howardi (Chattahoochee Crayfish) approx. 0.3 mi NE of site in Sope Creek

GA Crataegus triflora (Three-flowered Hawthorn) approx. 1.2 mi W of site 

GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.8 mi W of site 

GA Cyprinella callitaenia (Bluestripe Shiner) approx. 2.8 mi W of site in the Chattahoochee 

River

GA Cyprinella callitaenia (Bluestripe Shiner) approx. 1.2 mi W of site in Nancy Creek

GA Cypripedium acaule (Pink Ladyslipper) approx. 2.7 mi W of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 1.7 mi SW of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 1.3 mi SW of site 
IR 16742

Delphinium tricorne (Dwarf Larkspur) approx. 0.8 mi W of site 

GA Draba aprica (Sun-loving Draba) approx. 2.2 mi SW of site 

GA Draba aprica (Sun-loving Draba) approx. 2.1 mi SW of site 

GA Elliptio arctata (Delicate Spike) [HISTORIC] in an uncertain location near the project site 

US Etheostoma scotti (Cherokee Darter) approx. 2.2 mi NE of site in Kellogg Creek and 

Unnamed Tributaries

US Etheostoma scotti (Cherokee Darter) approx. 1.8 mi S of site in Proctor Creek

US Etheostoma scotti (Cherokee Darter) approx. 1.4 mi SW of site in Proctor Creek

US Etheostoma scotti (Cherokee Darter) approx. 2.5 mi SW of site in Westbrook Creek

US Etheostoma scotti (Cherokee Darter) on site in uncertain locations within Clarke Creek 

and Unnamed Tributaries

US Etheostoma scotti (Cherokee Darter) approx. 0.4 mi SW of site in Tanyard Creek

US Etheostoma scotti (Cherokee Darter) [HISTORIC] approx. 1.0 mi NE of site in Clarke 

Creek

US Etheostoma scotti (Cherokee Darter) [HISTORIC] approx. 2.8 mi N of site in Kellogg 

Creek

GA Falco peregrinus (Peregrine Falcon) approx. 0.5 mi E of site 

GA Fothergilla major (Mountain Witch-alder) approx. 1.0 mi NE of site 

Hemidactylium scutatum (Four-toed Salamander) approx. 1.9 mi S of site 

GA Hybopsis lineapunctata (Lined Chub) approx. 2.7 mi SW of site in Westbrook Creek

Hybopsis sp. 9 (Etowah Chub) [HISTORIC] approx. 2.8 mi NE of site in Stamp Creek

Melanthium latifolium (Broadleaf Bunchflower) [EXTIRPATED?] from an unknown 

location near the project site 

Micropterus cataractae (Shoal Bass) approx. 0.4 mi W of site in Nancy Creek

Micropterus cataractae (Shoal Bass) approx. 0.1 mi W of site in Peachtree Creek

Micropterus cataractae (Shoal Bass) approx. 1.2 mi NE of site in the Chattahoochee River

Myotis septentrionalis (Northern Myotis) approx. 2.6 mi NE of site 

GA Nestronia umbellula (Indian Olive) approx. 0.3 mi NE of site 

GA Nestronia umbellula (Indian Olive) [HISTORIC] in an uncertain location near the project 

site 

Nyctanassa violacea (Yellow-crowned Night-heron) in an uncertain location near the 

project site 

GA Pachysandra procumbens (Allegheny-spurge) approx. 0.6 mi W of site 

Perimyotis subflavus (Tri-colored Bat) approx. 0.4 mi SW of site 

Perimyotis subflavus (Tri-colored Bat) in an uncertain location near the project site 

Perimyotis subflavus (Tri-colored Bat) approx. 1.8 mi SW of site 

Perimyotis subflavus (Tri-colored Bat) [HISTORIC] in an uncertain location near the 

project site 

GA Peucaea aestivalis (Bachman's Sparrow) [HISTORIC] approx. 0.3 mi W of site 

Pituophis melanoleucus melanoleucus (Northern Pine Snake) approx. 0.7 mi SW of site 

US Platanthera integrilabia (Monkeyface Orchid) [EXTIRPATED] approx. 1.7 mi NE of site 

Plethodon websteri (Webster's Salamander) approx. 0.6 mi SW of site 

Pycnanthemum curvipes (Stone Mountain Mint) approx. 1.8 mi SW of site 

Quadrula infucata (Sculptured Pigtoe) [HISTORIC] in an uncertain location near the 

project site in the Chattahoochee River

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.3 mi NE of site 
IR 16742

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.5 mi N of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.8 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 0.8 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 2.2 mi E of site 

GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 1.9 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 0.2 mi SW of site 

GA Schisandra glabra (Bay Star-vine) in an uncertain location near the project site

GA Schisandra glabra (Bay Star-vine) approx. 0.9 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 0.1 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 0.5 mi W of site 

GA Schisandra glabra (Bay Star-vine) [EXTIRPATED] approx. 1.2 mi NE of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi SW of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 2.4 mi E of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 2.5 mi N of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 0.5 mi SW of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 0.1 mi NE of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 0.9 mi W of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 1.1 mi E of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 1.0 mi SW of site 

GA Symphyotrichum georgianum (Georgia Aster) in an uncertain location near the project site

GA Symphyotrichum georgianum (Georgia Aster) [EXTIRPATED?] approx. 1.2 mi SW of 

site 

Trillium lancifolium (Lanceleaf Trillium) approx. 1.7 mi S of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 0.2 mi SW of site 

Viburnum rafinesquianum var. rafinesquianum (Downy Arrowwood) approx. 1.3 mi W of 

site 

Zanthoxylum americanum (Northern Prickly-ash) approx. 1.4 mi SW of site 

Chattahoochee River National Recreation Area (NPS) on site

Clayton County Greenspace approx. 2.0 mi SE of site 

Cobb County Greenspace approx. 0.2 mi NE of site 

Cobb County Greenspace approx. 0.2 mi SW of site 

Cobb County Greenspace approx. 0.6 mi S of site 

Cobb County Greenspace approx. 1.2 mi SW of site 

Cobb County Greenspace approx. 1.5 mi NE of site 

Cobb County Greenspace approx. 1.5 mi SW of site 

Cobb County Greenspace approx. 1.9 mi NE of site 

Cobb County Greenspace approx. 1.9 mi SW of site 

Cobb County Greenspace approx. 2.6 mi W of site 

DeKalb County Greenspace approx. 2.9 mi E of site 

Fulton County Greenspace approx. 0.2 mi NW of site 

Fulton County Greenspace approx. 0.6 mi E of site 

Fulton County Greenspace approx. 1.2 mi E of site 

Fulton County Greenspace approx. 1.9 mi W of site 

Fulton County Greenspace approx. 3.0 mi W of site 

Kennesaw Mountain National Battlefield Park (NPS) approx. 1.4 mi W of site
IR 16742

Lake Allatoona (DOD/COE) on site

Jordan Cave approx. 1.8 mi SW of site 

Chattahoochee Upper North 1 (0313000111) [SWAP High Priority Watershed] on site 

Chattahoochee River Lower North 8 (0313000201) [SWAP High Priority Watershed] on 

site 

Chattahoochee River Lower North 7 (0313000203) [SWAP High Priority Watershed], 

approx. 2.6 mi W of site 

Flint River Upper 6 (0313000501) [SWAP High Priority Watershed] on site 

Little River, Etowah River, Allatoona Lake (0315010408) [SWAP High Priority 

Watershed] on site 

Allatoona Creek, Allatoona Lake (0315010409) [SWAP High Priority Watershed] on site 

Etowah River 4, Allatoona Lake (0315010410) [SWAP High Priority Watershed], approx. 

0.3 mi NE of site

Pumpkinvine Creek (0315010411) [SWAP High Priority Watershed] on site 

Etowah River 3 (0315010413) [SWAP High Priority Watershed] on site

I 75 Corridor (N of split) (Site Center: -84.970571, 34.624668, WGS84)

Aesculus glabra (Ohio Buckeye) approx. 1.0 mi NE of site 

Agalinis gattingeri (Gattinger's Purple Foxglove) in an uncertain location near the project 

site 

Amblema elliottii (Coosa Fiveridge) approx. 0.4 mi NE of site in the Oostanaula River

Amblema elliottii (Coosa Fiveridge) approx. 2.0 mi NE of site in the Conasauga River

Amblema elliottii (Coosa Fiveridge) [HISTORIC?] approx. 2.6 mi W of site in 

Oothkalooga Creek

Amorpha nitens (Shining Indigo-bush) in an uncertain location near the project site 

US Arabis georgiana (Georgia Rockcress) approx. 0.2 mi SW of site 

GA Aureolaria patula (Spreading Yellow Foxglove) approx. 2.8 mi SW of site 

Baptisia australis var. aberrans (Glade Blue Indigo) approx. 2.6 mi N of site 

Baptisia australis var. aberrans (Glade Blue Indigo) approx. 2.5 mi SW of site 

Bouteloua curtipendula (Side-oats Grama) approx. 1.8 mi SW of site 

Bouteloua curtipendula (Side-oats Grama) approx. 1.9 mi SW of site 

Bouteloua curtipendula (Side-oats Grama) approx. 2.5 mi SW of site 

Buchnera americana (Bluehearts) approx. 0.6 mi SW of site 

Calystegia catesbeiana ssp. sericata (Silky Bindweed) in an uncertain location near the 

project site 

Camassia scilloides (Wild Hyacinth) in an uncertain location near the project site

Camassia scilloides (Wild Hyacinth) approx. 1.9 mi NE of site 

Camassia scilloides (Wild Hyacinth) in an uncertain location near the project site

GA Cambarus extraneus (Chickamauga Crayfish) approx. 0.5 mi SW of site in an Unnamed 

Tributary to East Chickamauga Creek

GA Cambarus extraneus (Chickamauga Crayfish) approx. 2.1 mi NE of site in Little Tiger 

Creek

GA Cambarus extraneus (Chickamauga Crayfish) approx. 0.5 mi NE of site in Tiger Creek

GA Cambarus extraneus (Chickamauga Crayfish) approx. 2.4 mi NE of site in South 

Chickamauga Creek
IR 16742

GA Cambarus extraneus (Chickamauga Crayfish) in an uncertain location near the project site

in South Chickamauga Creek

GA Cambarus extraneus (Chickamauga Crayfish) [HISTORIC] approx. 2.1 mi SW of site in 

East Chickamauga Creek

GA Cambarus extraneus (Chickamauga Crayfish) [HISTORIC] approx. 2.8 mi SW of site in 

Peavine Creek

Carex buxbaumii (Brown Bog Sedge) in an uncertain location near the project site 

Carex grayi (Asa Gray's Sedge) approx. 0.3 mi SW of site 

Carex triangularis (Fox Sedge) approx. 0.3 mi SW of site 

Chaerophyllum procumbens (Spreading Chervil) approx. 0.2 mi SW of site 

Cheilanthes alabamensis (Alabama Lipfern) in an uncertain location near the project site

GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.1 mi NE of site 

GA Cryptobranchus alleganiensis alleganiensis (Eastern Hellbender) approx. 2.4 mi NE of 

site in South Chickamauga Creek

Cyprinella spiloptera (Spotfin Shiner) approx. 1.1 mi NE of site in Peavine Creek

Cyprinella spiloptera (Spotfin Shiner) approx. 1.0 mi SW of site in West Chickamauga 

Creek

Cyprinella spiloptera (Spotfin Shiner) approx. 0.1 mi SW of site in East Chickamauga 

Creek

Cyprinella spiloptera (Spotfin Shiner) approx. 0.3 mi E of site in South Chickamauga 

Creek

GA Cypripedium acaule (Pink Ladyslipper) approx. 1.1 mi W of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 1.3 mi W of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 3.0 mi W of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 2.3 mi E of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 0.5 mi SW of site 

GA Cypripedium parviflorum (Yellow Ladyslipper) approx. 1.3 mi W of site 

Dalea gattingeri (Gattinger Prairie Clover) approx. 1.9 mi SW of site 

Dalea gattingeri (Gattinger Prairie Clover) approx. 2.6 mi SW of site 

Dalea gattingeri (Gattinger Prairie Clover) approx. 1.8 mi SW of site 

Dalea gattingeri (Gattinger Prairie Clover) approx. 2.5 mi SW of site 

Dasistoma macrophylla (Mullein Foxglove) approx. 1.5 mi NE of site

Delphinium carolinianum ssp. calciphilum (Glade Larkspur) approx. 1.9 mi SW of site 

Delphinium carolinianum ssp. calciphilum (Glade Larkspur) approx. 1.8 mi SW of site 

Delphinium carolinianum ssp. calciphilum (Glade Larkspur) approx. 2.5 mi SW of site 

Delphinium tricorne (Dwarf Larkspur) in an uncertain location near the project site

Delphinium tricorne (Dwarf Larkspur) approx. 0.9 mi E of site 

Desmognathus aeneus (Seepage Salamander) approx. 2.6 mi SW of site 

Dryopteris celsa (Log Fern) approx. 1.5 mi NE of site 

Dryopteris celsa (Log Fern) approx. 0.9 mi NE of site 

Eleocharis compressa (Spikerush) approx. 2.6 mi SW of site 

Eleocharis compressa (Spikerush) approx. 1.9 mi SW of site 

Eleocharis compressa (Spikerush) approx. 2.5 mi SW of site 

GA Elliptio arca (Alabama Spike) approx. 2.7 mi E of site in the Coosawattee River

US Epioblasma metastriata (Upland Combshell) [HISTORIC] approx. 0.7 mi NE of site in 

the Conasauga River
IR 16742

US Epioblasma othcaloogensis (Southern Acornshell) approx. 2.3 mi W of site in 

Oothkalooga Creek

Erigenia bulbosa (Harbinger-of-spring) approx. 1.1 mi NE of site 

US Erimonax monachus (Spotfin Chub) [EXTIRPATED] approx. 0.8 mi N of site in South 

Chickamauga Creek

Etheostoma cinereum (Ashy Darter) [EXTIRPATED] approx. 2.3 mi NE of site in South 

Chickamauga Creek

GA Etheostoma ditrema (Coldwater Darter) approx. 0.6 mi SW of site in Camp Creek

GA Etheostoma ditrema (Coldwater Darter) approx. 1.9 mi W of site in Oothkalooga Creek

GA Etheostoma duryi (Blackside Snubnose Darter) approx. 0.7 mi NE of site in Tiger Creek

Etheostoma jessiae (Blueside Darter) approx. 2.0 mi SW of site in Tanyard Creek

Etheostoma jessiae (Blueside Darter) approx. 1.1 mi NE of site in Peavine Creek

Etheostoma jessiae (Blueside Darter) approx. 0.8 mi S of site in Little Chickamauga Creek

Etheostoma jessiae (Blueside Darter) approx. 0.4 mi NE of site in Tiger Creek

Etheostoma jessiae (Blueside Darter) approx. 0.1 mi SW of site in East Chickamauga 

Creek

Etheostoma jessiae (Blueside Darter) approx. 2.3 mi NE of site in South Chickamauga 

Creek

Etheostoma jessiae (Blueside Darter) in an uncertain location near the project site in South 

Chickamauga Creek

GA Etheostoma rupestre (Rock Darter) approx. 0.7 mi NE of site in the Conasauga River

US Etheostoma scotti (Cherokee Darter) approx. 0.1 mi SW of site in Pettit Creek and 

Unnamed Tributaries

GA Etheostoma trisella (Trispot Darter) approx. 1.0 mi NE of site in Haig Mill Creek

GA Etheostoma trisella (Trispot Darter) approx. 1.8 mi NE of site in the Conasauga River

GA Etheostoma trisella (Trispot Darter) approx. 2.7 mi E of site in Crane Eater Creek

GA Etheostoma trisella (Trispot Darter) approx. 2.5 mi NE of site in Swamp Creek

GA Etheostoma trisella (Trispot Darter) approx. 0.1 mi NE of site in Mill Creek

GA Etheostoma trisella (Trispot Darter) [HISTORIC] approx. 0.6 mi E of site in Little Swamp 

Creek

GA Fothergilla major (Mountain Witch-alder) in an uncertain location near the project site

Glyceria acutiflora (Sharp-scaled Manna-grass) [HISTORIC] approx. 0.3 mi SW of site 

Glyceria pallida (Pale Manna-grass) approx. 0.4 mi W of site

GA Graptemys geographica (Northern Map Turtle) approx. 2.3 mi NE of site 

GA Graptemys geographica (Northern Map Turtle) approx. 2.7 mi SW of site 

GA Graptemys geographica (Northern Map Turtle) [HISTORIC] approx. 0.6 mi NE of site 

GA Graptemys pulchra (Alabama Map Turtle) approx. 2.8 mi NE of site

GA Graptemys pulchra (Alabama Map Turtle) approx. 0.7 mi NE of site

GA Graptemys pulchra (Alabama Map Turtle) approx. 0.5 mi E of site 

GA Graptemys pulchra (Alabama Map Turtle) [HISTORIC] approx. 0.9 mi E of site

US Hamiota altilis (Finelined Pocketbook) [HISTORIC] in an uncertain location near the 

project site in a tributary to the Conasauga River

Helianthus occidentalis (Barrens Sunflower) approx. 2.5 mi SW of site 

Helianthus occidentalis (Barrens Sunflower) approx. 2.4 mi SW of site 

GA Hemitremia flammea (Flame Chub) approx. 0.5 mi NE of site in Lower Tiger Creek and 

associated tributaries
IR 16742

GA Hemitremia flammea (Flame Chub) approx. 0.5 mi SW of site in an Unnamed Tributary to 

East Chickamauga Creek

Hiodon tergisus (Mooneye) approx. 0.6 mi E of site in the Coosawattee River

Hottonia inflata (Featherfoil) approx. 0.3 mi SW of site 

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 0.8 mi NE of site in the 

Oostanaula River

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 0.7 mi E of site in Swamp 

Creek

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 1.4 mi E of site in Drowning 

Bear Creek

Hydrophyllum macrophyllum (Largeleaf Waterleaf) approx. 1.6 mi E of site 

Hypericum dolabriforme (Glade St. Johnswort) approx. 2.6 mi SW of site 

Hypericum dolabriforme (Glade St. Johnswort) approx. 2.5 mi SW of site 

Hypericum dolabriforme (Glade St. Johnswort) approx. 1.9 mi SW of site 

GA Ichthyomyzon bdellium (Ohio Lamprey) on site in East Chickamauga Creek (-85.14525, 

34.97749 WGS84)

GA Ichthyomyzon bdellium (Ohio Lamprey) approx. 0.2 mi N of site in South Chickamauga 

Creek

GA Ichthyomyzon bdellium (Ohio Lamprey) approx. 0.8 mi S of site in Little Chickamauga 

Creek

Iris prismatica (Slender Blue Flag) approx. 0.9 mi SW of site 

Iris prismatica (Slender Blue Flag) approx. 0.4 mi SW of site 

Juncus filipendulus (Texas Plains Rush) approx. 1.8 mi SW of site 

Juncus filipendulus (Texas Plains Rush) approx. 2.5 mi SW of site 

Juncus filipendulus (Texas Plains Rush) approx. 1.9 mi SW of site 

Lampropeltis triangulum triangulum (Eastern Milk Snake) [HISTORIC] approx. 1.4 mi 

NE of site 

Lampsilis fasciola (Wavy-rayed Lampmussel) approx. 0.2 mi N of site in South 

Chickamauga Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.5 mi E of site in Crow Valley 

Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.7 mi E of site in Poplar Spring 

Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.1 mi SW of site in Two Run Creek

Lasmigona etowaensis (Etowah Heelsplitter) in an uncertain location near the project site

in the Conasauga River

Lasmigona etowaensis (Etowah Heelsplitter) approx. 0.3 mi SW of site in Pettit Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.2 mi SWof site in Pettit Creek 

Unnamed Tributary

Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] in an uncertain location near 

the project site in Swamp Creek

GA Leavenworthia exigua var. exigua (Least Gladecress) approx. 2.6 mi SW of site 

GA Leavenworthia exigua var. exigua (Least Gladecress) approx. 1.9 mi SW of site 

GA Leavenworthia exigua var. exigua (Least Gladecress) approx. 1.8 mi SW of site 

GA Leavenworthia exigua var. exigua (Least Gladecress) approx. 2.5 mi SW of site 
IR 16742

Leptoxis praerosa (Onyx Rocksnail) approx. 0.2 mi N of site in South Chickamauga 

Creek

Liatris squarrosa var. hirsuta (Glade Gay-feather) approx. 2.6 mi SW of site 

Liatris squarrosa var. hirsuta (Glade Gay-feather) approx. 1.8 mi SW of site 

Liatris squarrosa var. hirsuta (Glade Gay-feather) approx. 1.9 mi SW of site 

US Lioplax cyclostomaformis (Cylindrical Lioplax) [HISTORIC] in an uncertain location near 

the project site in Oothkalooga Creek

Lythrurus lirus (Mountain Shiner) approx. 0.7 mi NE of site in Tiger Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.7 mi W of site in Lynn Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 2.6 mi W of site in Mud Crek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.7 mi E of site in Swamp Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 2.5 mi NE of site in Swamp 

Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.6 mi E of site in Little Swamp 

Creek

GA Macrhybopsis sp. 1 (Coosa Chub) approx. 2.6 mi E of site in the Coosawattee River

Macrhybopsis storeriana (Silver Chub) approx. 1.2 mi E of site in the Coosawattee River

Macrhybopsis storeriana (Silver Chub) approx. 0.8 mi NE of site in the Oostanaula River

Matelea obliqua (Limerock Milkvine) in an uncertain location near the project site

US Medionidus acutissimus (Alabama Moccasinshell) [HISTORIC] in an uncertain location 

near the project site in Swamp Creek

US Medionidus parvulus (Coosa Moccasinshell) [HISTORIC] approx. 0.7 mi NE of site in the 

Conasauga River

US Medionidus parvulus (Coosa Moccasinshell) [HISTORIC] in an uncertain location near 

the project site in Swamp Creek

Mertensia virginica (Virginia Bluebells) approx. 1.1 mi NE of site 

Mertensia virginica (Virginia Bluebells) approx. 1.1 mi E of site 

Moxostoma anisurum (Silver Redhorse) approx. 2.4 mi NE of site in South Chickamauga 

Creek

GA Moxostoma carinatum (River Redhorse) approx. 1.6 mi NE of site in the Coosawattee/ 

Conasauga near Confluence

GA Moxostoma carinatum (River Redhorse) approx. 2.4 mi NE of site in South Chickamauga 

Creek

GA Moxostoma carinatum (River Redhorse) approx. 0.6 mi E of site in the Oostanaula River

US Myotis grisescens (Gray Myotis) approx. 2.0 mi NE of site 

US Myotis grisescens (Gray Myotis) approx. 0.1 mi N of site 

US Myotis grisescens (Gray Myotis) approx. 1.1 mi NE of site 

US Myotis grisescens (Gray Myotis) approx. 1.5 mi W of site 

US Myotis grisescens (Gray Myotis) approx. 1.4 mi W of site 

US Myotis septentrionalis (Northern Myotis) approx. 1.8 mi NE of site 

Necturus maculosus (Mudpuppy) [HISTORIC] approx. 1.1 mi S of site in Little 

Chickamauga Creek

GA Notropis ariommus (Popeye Shiner) approx. 0.2 mi N of site in South Chickamauga Creek

GA Notropis ariommus (Popeye Shiner) [HISTORIC] approx. 0.3 mi N of site in an Unnamed 

Tributary to Chickamauga Creek

GA Notropis asperifrons (Burrhead Shiner) approx. 0.7 mi E of site in Swamp Creek
IR 16742

Notropis atherinoides (Emerald Shiner) approx. 2.2 mi SW of site in West Chickamauga 

Creek

Notropis atherinoides (Emerald Shiner) approx. 1.1 mi E of site in South Chickamauga 

Creek

GA Notropis photogenis (Silver Shiner) approx. 2.4 mi NE of site in South Chickamauga 

Creek

Notropis volucellus (Mimic Shiner) approx. 2.3 mi NE of site in South Chickamauga 

Creek

Notropis volucellus (Mimic Shiner) approx. 0.1 mi N of site in South Chickamauga Creek

Notropis volucellus (Mimic Shiner) approx. 0.1 mi SW of site in East Chickamauga Creek

Notropis volucellus (Mimic Shiner) [HISTORIC] approx. 0.5 mi NE of site in Tiger Creek

GA Noturus eleutherus (Mountain Madtom) approx. 0.3 mi E of site in South Chickamauga 

Creek

Oldenlandia boscii (Bluets) in an uncertain location near the project site

Ophioglossum engelmannii (Limestone Adder's-tongue) approx. 2.5 mi SW of site 

Orconectes forceps (Surgeon crayfish) approx. 0.8 mi NE of site in Tiger Creek

Panax quinquefolius (American Ginseng) approx. 1.0 mi W of site 

Panax quinquefolius (American Ginseng) approx. 1.1 mi E of site 

Panax quinquefolius (American Ginseng) approx. 2.0 mi E of site 

Panax quinquefolius (American Ginseng) approx. 1.1 mi NE of site 

Parietaria pensylvanica (Pennsylvania Pellitory) approx. 0.2 mi SW of site 

Pediomelum subacaule (Nashville Breadroot) approx. 2.6 mi SW of site 

Pediomelum subacaule (Nashville Breadroot) approx. 1.9 mi SW of site 

Pediomelum subacaule (Nashville Breadroot) approx. 1.8 mi SW of site 

Pediomelum subacaule (Nashville Breadroot) approx. 2.5 mi SW of site 

Percina sciera (Dusky Darter) approx. 0.1 mi N of site in Chickamauga Creek

Percina sciera (Dusky Darter) in an uncertain location near the project site Little 

Chickamauga Creek

Percina sciera (Dusky Darter) approx. 1.1 mi NE of site in Peavine Creek

Percina sciera (Dusky Darter) approx. 0.4 mi NE of site in Tiger Creek

Percina sciera (Dusky Darter) approx. 0.3 mi SW of site in East Chickamauga Creek

Perimyotis subflavus (Tri-colored Bat) approx. 0.5 mi E of site 

Perimyotis subflavus (Tri-colored Bat) approx. 0.1 mi NE of site 

Perimyotis subflavus (Tri-colored Bat) approx. 1.9 mi W of site 

Perimyotis subflavus (Tri-colored Bat) approx. 0.9 mi SW of site 

Perimyotis subflavus (Tri-colored Bat) approx. 1.2 mi N of site 

GA Phenacobius uranops (Stargazing Minnow) approx. 0.3 mi SW of site in East 

Chickamauga Creek

GA Phenacobius uranops (Stargazing Minnow) approx. 1.0 mi SW of site in West 

Chickamauga Creek

GA Phenacobius uranops (Stargazing Minnow) E, 2007-10-11, Tiger Creek, approx. 0.8 mi 

NE of site 

GA Phenacobius uranops (Stargazing Minnow) E, 2014-08-26, South Chickamauga Creek 

Upstream of Graysville Dam, on site in South Chickamauga Creek

Phlox amplifolia (Broadleaf Phlox) , 1992-07-31, , approx. 1.4 mi W of site 
IR 16742

US Pleurobema decisum (Southern Clubshell) H?, 1997-09-06, Conasauga River Near 

Resaca, approx. 0.7 mi NE of site in the Conasauga River

US Pleurobema decisum (Southern Clubshell) H?, 2005-08-15, Oothkalooga Creek Near 

Calhoun, approx. 2.2 mi W of site Oothkalooga Creek

US Pleurobema georgianum (Southern Pigtoe) H, 1974-PRE, Oothkalooga Creek, approx. 2.3 

mi W of site Oothkalooga Creek

US Pleurobema georgianum (Southern Pigtoe) H, 1974-PRE, Swamp Creek, on site 

Pleurocera pyrenella (Skirted Hornsnail) approx. 0.2 mi N of site in Chickamauga Creek

Pleurocera pyrenella (Skirted Hornsnail) approx. 0.8 mi S of site in Little Chickamauga 

Creek

Pleurocera pyrenella (Skirted Hornsnail) approx. 1.0 mi SW of site in West Chickamauga 

Creek

Pleurocera pyrenella (Skirted Hornsnail) in an uncertain location near the project site in 

Mill Creek

Pleurocera pyrenella (Skirted Hornsnail) [HISTORIC?] approx. 0.5 mi SW of site in 

Peavine Creek

Pleurocera showalteri (Upland Hornsnail) [HISTORIC] approx. 0.9 mi W of site in the 

Oostanaula River

Pleuronaia barnesiana (Tennessee Pigtoe) approx. 0.8 mi NE of site in Tiger Creek

Pleuronaia barnesiana (Tennessee Pigtoe) [HISTORIC?] approx. 0.3 mi N of site in 

South Chickamauga Creek

Polemonium reptans (Jacobs Ladder) approx. 0.3 mi SW of site 

Polemonium reptans (Jacobs Ladder) approx. 1.1 mi E of site 

Polemonium reptans (Jacobs Ladder) approx. 1.1 mi NE of site 

Polemonium reptans (Jacobs Ladder) approx. 1.4 mi E of site 

Polemonium reptans (Jacobs Ladder) in an uncertain location near the project site

Ptilimnium costatum (Eastern Bishopweed) approx. 0.6 mi S of site 

Ptychobranchus fasciolaris (Kidneyshell) approx. 0.2 mi N of site 

US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 2.7 mi E of site in the 

Coosawattee River

US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 0.7 mi NE of site in the 

Conasauga River

Quadrula asperata (Alabama Orb) approx. 2.3 mi W of site in the Oostanaula River

Quadrula rumphiana (Ridged Mapleleaf) approx. 0.3 mi SW of site in the Oostanaula 

River

Quadrula rumphiana (Ridged Mapleleaf) approx. 2.0 mi NE of site in the Conasauga 

River

Quadrula rumphiana (Ridged Mapleleaf) approx. 0.9 mi E of site in the Coosawattee 

River

Quadrula rumphiana (Ridged Mapleleaf) [HISTORIC?] approx. 2.6 mi W of site 

Oothkalooga Creek

Quercus palustris (Pin Oak) in an uncertain location near the project site 

Rudbeckia grandiflora (Largeflower Coneflower) approx. 1.1 mi NE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.8 mi NE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.9 mi SE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.4 mi NE of site 
IR 16742

GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] approx. 1.8 mi NE of site 

GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] approx. 0.3 mi SE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.2 mi SW of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.2 mi E of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.5 mi E of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.6 mi SE of site 

GA Schisandra glabra (Bay Star-vine) approx. 1.7 mi SE of site 

Scutellaria leonardii (Glade Skullcap) approx. 2.6 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.2 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) in an uncertain location near the project 

site

US Scutellaria montana (Large-flowered Skullcap) approx. 2.2 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.3 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.3 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.8 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.8 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.1 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.9 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.3 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.9 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.1 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.9 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.5 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.2 mi E of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.0 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 3.0 mi NE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.5 mi E of site 

Silphium radula (Rosinweed) approx. 1.1 mi NE of site 

Sorex hoyi (Pygmy Shrew) approx. 2.9 mi W of site 

GA Spiranthes magnicamporum (Great Plains Ladies-tresses) approx. 2.9 mi SW of site 

GA Spiranthes magnicamporum (Great Plains Ladies-tresses) [EXTIRPATED] approx. 2.5 mi 

SW of site 

GA Spiranthes magnicamporum (Great Plains Ladies-tresses) [EXTIRPATED] approx. 2.7 mi 

SW of site 

GA Spiranthes magnicamporum (Great Plains Ladies-tresses) [EXTIRPATED?] approx. 2.5 

mi SW of site 
IR 16742

Spiranthes ovalis var. erostellata (Self-pollinating Oval Ladies-tresses) approx. 1.3 mi E 

of site 

Sporobolus heterolepis (Prairie Dropseed) approx. 2.6 mi SW of site 

Sporobolus heterolepis (Prairie Dropseed) approx. 1.8 mi SW of site 

Sporobolus heterolepis (Prairie Dropseed) approx. 2.5 mi SW of site 

Sporobolus heterolepis (Prairie Dropseed) approx. 1.9 mi SW of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 0.2 mi NW of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 2.0 mi SW of site 

GA Symphyotrichum georgianum (Georgia Aster) [EXTIRPATED?] approx. 2.6 mi E of site 

GA Thalictrum debile (Trailing Meadowrue) on site (-84.91981, 34.43000 WGS84)

GA Thaspium pinnatifidum (Glade Meadowparsnip) [EXTIRPATED] approx. 2.6 mi SW of 

site 

Thryomanes bewickii (Bewick's Wren) approx. 1.8 mi E of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 1.4 mi E of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 1.6 mi E of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 1.5 mi E of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 0.4 mi E of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 1.4 mi W of site

GA Trillium pusillum (Dwarf Trillium) approx. 1.6 mi E of site 

GA Trillium pusillum (Dwarf Trillium) approx. 1.4 mi E of site 

GA Trillium pusillum (Dwarf Trillium) approx. 1.7 mi E of site 

Villosa trabalis (Cumberland Bean) [EXTIRPATED] in an uncertain location near the 

project site 

Villosa umbrans (Coosa Creekshell) approx. 0.5 mi W of site in Oothkalooga Creek

Villosa umbrans (Coosa Creekshell) in an uncertain location near the project site in the 

Conasauga River

Villosa umbrans (Coosa Creekshell) approx. 0.2 mi SW of site in Swamp Creek

Villosa umbrans (Coosa Creekshell) [HISTORIC] approx. 0.9 mi E of site in New Town 

Creek

Villosa vanuxemensis (Mountain Creekshell) approx. 0.2 mi N of site South Chickamauga 

Creek

Villosa vanuxemensis (Mountain Creekshell) [HISTORIC?] approx. 1.9 mi W of site in 

Mill Creek

Viola egglestonii (Glade Violet) approx. 2.6 mi SW of site 

Viola egglestonii (Glade Violet) approx. 1.9 mi SW of site 

Viola egglestonii (Glade Violet) approx. 2.5 mi SW of site 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 2.7 mi NE of site 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 2.1 mi SW of site 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 2.6 mi SW of site 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 3.0 mi W of site 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) on site (-84.78139, 34.24805 

WGS84) 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 2.0 mi NE of site 

Catoosa County Greenspace approx. 0.3 mi N of site 

Catoosa County Greenspace approx. 0.5 mi N of site 

Catoosa County Greenspace approx. 0.6 mi S of site 
IR 16742

Catoosa County Greenspace approx. 0.9 mi N of site 

Catoosa County Greenspace approx. 1.0 mi N of site 

Catoosa County Greenspace approx. 1.0 mi SW of site 

Catoosa County Greenspace approx. 2.2 mi NE of site 

Catoosa County Greenspace on site 

Forest, sagpond (Sagpond Forest) approx. 0.2 mi SW of site 

Forest, sagpond (Sagpond Forest) approx. 2.0 mi NE of site 

Gordon County Greenspace on site 

Pinus palustris - Pinus echinata - (Pinus virginiana) / Quercus marilandica - (Quercus 

prinus) / Vaccinium pallidum Woodland (Montane Mixed Longleaf Woodland) 

approx. 2.6 mi NE of site 

Quercus (pagoda, phellos, shumardii) - Celtis laevigata / Cornus foemina / Podophyllum 

peltatum - Hymenocallis occidentalis Flatwoods Forest (Southern Ridge and Valley 

Calcareous Flatwoods Forest) on site 

Quercus (pagoda, phellos, shumardii) - Celtis laevigata / Cornus foemina / Podophyllum 

peltatum - Hymenocallis occidentalis Flatwoods Forest (Southern Ridge and Valley 

Calcareous Flatwoods Forest) approx. 1.4 mi E of site 

Shrub/scrub veg. sagpond (Sagpond Scrub-shrub) approx. 0.8 mi SW of site 

Whitfield County Greenspace on site 

Antioch Church Cave approx. 2.0 mi E of site 

Boyd Mountain Cave approx. 2.9 mi SW of site 

Chapman's Cave approx. 1.2 mi N of site 

Chert Chasm approx. 1.7 mi NE of site 

Chickamauga Cave approx. 2.2 mi NE of site 

Glenn Richard's Cave approx. 2.2 mi W of site 

Goodson Bend #1 [Cave], approx. 1.9 mi NE of site 

Goodson Bend #2 [Cave], approx. 1.9 mi NE of site 

Howard Hughes Cave approx. 2.1 mi NE of site 

Hunter's Cave approx. 2.1 mi SW of site 

Impressive Fern Pud [Cave], approx. 2.2 mi NE of site 

Jonboat Cave approx. 1.7 mi E of site 

Lost Creek Cave approx. 2.0 mi NE of site 

Lost Creek Cave approx. 2.2 mi NE of site 

Maggie Cox Cave approx. 0.2 mi E of site 

Mo Hole [Cave], approx. 0.2 mi NE of site 

Moss Lake Cave approx. 0.7 mi E of site 

Resaca Cave approx. 0.3 mi SW of site 

Resaca Battlefield HS (GA DNR) on site

Ridge Cave approx. 2.1 mi SW of site 

Chattahoochee NF (USFS) on site

Union Grove Church Cave approx. 2.0 mi E of site 

Whiteoak Mtn Cave approx. 0.3 mi N of site 

Yarbrough Cave approx. 0.3 mi NE of site 

Coahulla Creek (0315010103) [SWAP High Priority Watershed] on site 

Conasauga River 1 (0315010105) [SWAP High Priority Watershed] on site 
IR 16742

Coosawatee River 1 (0315010208) [SWAP High Priority Watershed] approx. 1.0 mi E of 

site 

Oostanaula River 2 (0315010301) [SWAP High Priority Watershed] on site 

Armuchee Creek (0315010305) [SWAP High Priority Watershed] approx. 2.9 mi W of 

site 

Allatoona Creek, Allatoona Lake (0315010409) [SWAP High Priority Watershed] approx. 

2.0 mi SE of site 

Etowah River 4, Allatoona Lake (0315010410) [SWAP High Priority Watershed] on site 

Pumpkinvine Creek (0315010411) [SWAP High Priority Watershed] approx. 2.4 mi S of 

site 

Etowah River 3 (0315010413) [SWAP High Priority Watershed] on site 

Etowah River 2 (0315010415) [SWAP High Priority Watershed] on site 

Chickamauga Creek (0602000108) [SWAP High Priority Watershed] on site 

Little Chickamauga Creek (0602000109) [SWAP High Priority Watershed] on site 

Chattanooga Creek (0602000111) [SWAP High Priority Watershed] approx. 0.3 mi S of 

site

East Corridor (N of split) 

Acipenser fulvescens (Lake Sturgeon) on site in the Coosawattee River (-84.69623, 

34.60420 WGS84)

Acorus americanus (Sweetflag) on site (-84.75361, 34.27111 WGS84)

Aesculus glabra (Ohio Buckeye) approx. 1.1 mi SW of site 

Agastache nepetoides (Yellow Giant Hyssop) on site (-84.6959, 34.60108 WGS84)

Baptisia australis var. aberrans (Glade Blue Indigo) approx. 0.5 mi SW of site 

Camassia scilloides (Wild Hyacinth) in an uncertain location near the project site 

Cambarus conasaugaensis (Mountain crayfish) approx. 2.4 mi NE of site in Unnamed 

Tributary to Holly Creek

Cambarus conasaugaensis (Mountain crayfish) approx. 2.3 mi E of site in Wolf Branch

GA Cambarus cymatilis (Conasauga Blue Burrower) approx. 2.3 mi N of site 

GA Cambarus extraneus (Chickamauga Crayfish) [HISTORIC] approx. 0.2 mi NE of site in 

Hurricane Creek

Cambarus manningi (Greensaddle crayfish) [HISTORIC] approx. 2.6 mi N of site in Mills 

Creek

GA Cambarus speciosus (Beautiful Crayfish) approx. 2.3 mi E of site in Wolf Branch

Cambarus stockeri (Cocoa Crayfish) in an uncertain location near the project site

Cambarus stockeri (Cocoa Crayfish) approx. 0.6 mi S of site in Pitner Branch

Cambarus stockeri (Cocoa Crayfish) approx. 3.0 mi NE of site in Seepage Area at Bagby 

Loop

Cambarus stockeri (Cocoa Crayfish) approx. 2.5 mi N of site in an Unnamed Tributary to 

Holly Creek

Campeloma regulare (Cylinder campeloma) approx. 2.5 mi E of site in the Conasauga 

River

Chaerophyllum procumbens (Spreading Chervil) approx. 2.5 mi SW of site 

Cornus drummondii (Midwestern Roughleaf Dogwood) approx. 0.2 mi E of site 

GA Cryptobranchus alleganiensis alleganiensis (Eastern Hellbender) in an uncertain location 

near the project site in South Chickamauga Creek
IR 16742

GA Cryptobranchus alleganiensis alleganiensis (Eastern Hellbender) [HISTORIC] approx. 

0.8 mi S of site in Tiger Creek

US Cyprinella caerulea (Blue Shiner), in an uncertain location near the project site in Rock 

Creek

US Cyprinella caerulea (Blue Shiner) approx. 0.5 mi N of site in Holly Creek

US Cyprinella caerulea (Blue Shiner) approx. 0.7 mi N of site in the Conasauga River

US Cyprinella caerulea (Blue Shiner) [HISTORIC] in an uncertain location near the project 

site in Chicken Creek

GA Cypripedium acaule (Pink Ladyslipper) approx. 2.3 mi E of site 

GA Cypripedium acaule (Pink Ladyslipper) on site (-84.99311, 34.94281 WGS84)

GA Cypripedium acaule (Pink Ladyslipper) approx. 2.8 mi NE of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 0.4 mi W of site 

Dasistoma macrophylla (Mullein Foxglove) approx. 1.5 mi SW of site 

Delphinium tricorne (Dwarf Larkspur) approx. 0.6 mi NW of site 

Desmognathus aeneus (Seepage Salamander) [HISTORIC?] approx. 2.4 mi NE of site 

Dryopteris celsa (Log Fern) approx. 0.9 mi NE of site 

GA Elliptio arca (Alabama Spike) approx. 1.0 mi E of site in the Conasauga River

US Epioblasma metastriata (Upland Combshell) [HISTORIC] approx. 1.3 mi S of site in the 

Conasauga River

US Epioblasma othcaloogensis (Southern Acornshell) [EXTIRPATED] approx. 0.3 mi N of 

site in the Conasauga River

Erigenia bulbosa (Harbinger-of-spring) in an uncertain location near the project site 

US Erimonax monachus (Spotfin Chub) [EXTIRPATED] approx. 2.0 mi SW of site 

in South Chickamauga Creek

Etheostoma cinereum (Ashy Darter) [EXTIRPATED] on site in South Chickamauga 

Creek (-85.14570, 34.97817 WGS84)

GA Etheostoma ditrema (Coldwater Darter) approx. 1.9 mi N of site in Cohutta Springs and 

Spring Run

GA Etheostoma ditrema (Coldwater Darter) [HISTORIC?] approx. 2.7 mi NE of site in Estelle 

Spring

GA Etheostoma ditrema (Coldwater Darter) [EXTIRPATED] approx. 2.5 mi N of site in Sand 

Spring

GA Etheostoma duryi (Blackside Snubnose Darter) approx. 2.6 mi S of site in Tiger Creek

Etheostoma jessiae (Blueside Darter) approx. 0.5 mi NE of site in Hurricane Creek

Etheostoma jessiae (Blueside Darter) approx. 0.8 mi S of site in Tiger Creek

Etheostoma jessiae (Blueside Darter) on site in South Chickamauga Creek (-85.14527, 

34.97860 WGS84)

GA Etheostoma rupestre (Rock Darter) in an uncertain location near the project site in 

Coahulla Creek 

GA Etheostoma rupestre (Rock Darter) in an uncertain location near the project site in the 

Conasauga River

GA Etheostoma rupestre (Rock Darter) approx. 0.3 mi N of site in the Conasauga River

GA Etheostoma trisella (Trispot Darter) approx. 1.2 mi W of site in Rock Creek

GA Etheostoma trisella (Trispot Darter) approx. 1.6 mi W of site in Sugar Creek

GA Etheostoma trisella (Trispot Darter) approx. 1.2 mi S of site in the Conasauga River

GA Etheostoma trisella (Trispot Darter) approx. 2.5 mi W of site in Dry Creek
IR 16742

GA Etheostoma trisella (Trispot Darter) in an uncertain location near the project site in 

Pinhook Creek

GA Etheostoma trisella (Trispot Darter) approx. 1.1 mi W of site in Mill Creek

GA Etheostoma trisella (Trispot Darter) approx. 0.9 mi SE of site in Coahulla Creek

GA Etheostoma trisella (Trispot Darter) approx. 0.1 mi W of site in Coosawattee River

GA Etheostoma trisella (Trispot Darter) approx. 0.6 mi W of site in Salacoa Creek

GA Etheostoma trisella (Trispot Darter) approx. 0.5 mi N of site in Holly Creek

GA Etheostoma trisella (Trispot Darter) approx. 0.3 mi NE of site in the Conasauga River

GA Etheostoma trisella (Trispot Darter) approx. 2.7 mi NE of site in an Unnamed Tributary to 

Conasauga River

Eurycea aquatica (Brown-backed Salamander) approx. 2.3 mi W of site 

GA Gomphus consanguis (Cherokee Clubtail) approx. 0.8 mi S of site in Tiger Creek

GA Graptemys geographica (Northern Map Turtle) in an uncertain location near the project 

site 

GA Graptemys geographica (Northern Map Turtle) [HISTORIC] approx. 2.3 mi NE of site 

GA Graptemys pulchra (Alabama Map Turtle) [HISTORIC] approx. 2.3 mi NE of site 

GA Graptemys pulchra (Alabama Map Turtle) [HISTORIC] in an uncertain location near the 

project site 

GA Haliaeetus leucocephalus (Bald Eagle) approx. 1.2 mi E of site 

US Hamiota altilis (Finelined Pocketbook) approx. 1.3 mi W of site in Rock Creek

US Hamiota altilis (Finelined Pocketbook) approx. 0.1 mi NE of site in the Conasauga River

US Hamiota altilis (Finelined Pocketbook) [HISTORIC] in an uncertain location near the 

project site in Coahulla Creek

US Hamiota altilis (Finelined Pocketbook) [HISTORIC] approx. 1.6 mi S of site in Holly 

Creek

Helianthus smithii (Smith Sunflower) approx. 2.6 mi SE of site 

GA Hemitremia flammea (Flame Chub) approx. 0.4 mi N of site in a tributary to Sugar Creek

GA Hemitremia flammea (Flame Chub) approx. 1.1 mi N of site in Dry Creek

GA Hemitremia flammea (Flame Chub) approx. 0.8 mi S of site in Lower Tiger Creek and

Tributaries

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] in an uncertain location near the 

project site in an Unnamed Coosawattee River Tributary

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 0.1 mi W of site in the 

Coosawattee River Tributary

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] on site in a Holly Creek Tributary 

(-84.74768, 34.72164 WGS84)

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 0.4 mi W of site in Rock 

Creek

Hydrophyllum macrophyllum (Largeleaf Waterleaf) on site (-84.69634, 34.60011 WGS84)

Hypericum dolabriforme (Glade St. Johnswort) approx. 0.3 mi W of site 

GA Ichthyomyzon bdellium (Ohio Lamprey) on site in East Chickamauga Creek (-85.14525, 

34.97749 WGS84)

Juncus filipendulus (Texas Plains Rush) approx. 0.3 mi W of site 

Lampetra aepyptera (Least Brook Lamprey) approx. 1.4 mi N of site in Mills Creek

Lampetra aepyptera (Least Brook Lamprey) approx. 1.1 mi E of site in the Conasauga 

River
IR 16742

Lampropeltis triangulum triangulum (Eastern Milk Snake) [HISTORIC] approx. 0.1 mi E 

of site 

Lasmigona etowaensis (Etowah Heelsplitter) approx. 2.9 mi W of site in Poplar Spring 

Creek

Lasmigona etowaensis (Etowah Heelsplitter) in an uncertain location near the project site 

in an Unnamed Tributary to Sugar Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.4 mi W of site in Pettit Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 1.3 mi SW of site in an Unnamed 

Tributary to Pettit Creek

Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] approx. 1.6 mi W of site in 

Kenyon (Spring) Creek

Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] approx. 2.3 mi SW of site in 

Little Creek

Lasmigona etowaensis (Etowah Heelsplitter) [HISTORIC] approx. 2.2 mi N of site in 

Mills Creek

Leavenworthia uniflora (Gladecress) approx. 0.3 mi W of site 

US Lioplax cyclostomaformis (Cylindrical Lioplax) [HISTORIC] in an uncertain location near 

the project site in Coahulla Creek

Lythrurus lirus (Mountain Shiner) approx. 1.6 mi W of site in Sugar Creek

Lythrurus lirus (Mountain Shiner) approx. 2.5 mi W of site in Dry Creek

Lythrurus lirus (Mountain Shiner) approx. 2.6 mi S of site in Tiger Creek

Lythrurus lirus (Mountain Shiner) approx. 0.7 mi E of site in Coahulla Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 1.4 mi N of site in Mill Creek

GA Macrhybopsis sp. 1 (Coosa Chub) approx. 0.2 mi W of site in Mill Creek

GA Macrhybopsis sp. 1 (Coosa Chub) approx. 2.3 mi SW of site in the Conasauga River

GA Macrhybopsis sp. 1 (Coosa Chub) approx. 0.1 mi W of site in Coosawattee River

GA Macrhybopsis sp. 1 (Coosa Chub) [EXTIRPATED?] approx. 0.2 mi NE of site in the 

Conasauga River

Macrhybopsis storeriana (Silver Chub) approx. 0.1 mi NE of site in the Conasauga River

US Medionidus acutissimus (Alabama Moccasinshell) [HISTORIC] in an uncertain location 

near the project site in Coahulla Creek

Mertensia virginica (Virginia Bluebells) in an uncertain location near the project site 

Moxostoma anisurum (Silver Redhorse) on site in East Chickamauga Creek 

(-85.14514, 34.97783 WGS84)

GA Moxostoma carinatum (River Redhorse) in an uncertain location near the project site in 

the Coosawattee River

GA Moxostoma carinatum (River Redhorse) approx. 2.2 mi SW of site in Holly Creek

GA Moxostoma carinatum (River Redhorse) on site in the Conasauga River (-84.87157, 

34.73594 WGS84)

GA Moxostoma carinatum (River Redhorse) on site in East Chickamauga Creek (-85.14525 

34.97789 WGS84) 

GA Moxostoma carinatum (River Redhorse) approx. 2.3 mi NE of site in the Conasauga River

US Myotis grisescens (Gray Myotis) approx. 0.8 mi SW of site 

US Myotis grisescens (Gray Myotis) approx. 3.0 mi SW of site 

US Myotis grisescens (Gray Myotis) approx. 2.0 mi S of site 

US Myotis grisescens (Gray Myotis) approx. 0.9 mi S of site 
IR 16742

Myotis leibii (Eastern Small-footed Myotis) approx. 3.0 mi NE of site 

GA Notropis ariommus (Popeye Shiner) in an uncertain location near the project site in East 

Chickamauga Creek 

GA Notropis asperifrons (Burrhead Shiner) in an uncertain location near the project site in 

Rock Creek

Notropis atherinoides (Emerald Shiner) an uncertain location near the project site in East 

Chickamauga Creek

GA Notropis photogenis (Silver Shiner) on site in East Chickamauga Creek (-85.14523, 

34.97785 WGS84)

Notropis volucellus (Mimic Shiner) on site in East Chickamauga Creek (-85.14596, 

34.97843 WGS84)

Notropis volucellus (Mimic Shiner) [HISTORIC] approx. 2.6 mi S of site in Tiger Creek

GA Noturus munitus (Frecklebelly Madtom) approx. 0.3 mi N of site 

Orconectes forceps (Surgeon crayfish) approx. 2.5 mi S of site in Tiger Creek

Panax quinquefolius (American Ginseng) approx. 1.1 mi SW of site 

Parnassia grandifolia (Largeleaf Grass-of-Parnassus) approx. 0.2 mi N of site 

US Percina antesella (Amber Darter) approx. 0.6 mi S of site in the Conasauga River

US Percina antesella (Amber Darter) approx. 0.3 mi N of site in the Conasauga River

US Percina aurolineata (Goldline Darter) approx. 0.1 mi W of site in the Coosawattee River

US Percina aurolineata (Goldline Darter) approx. 2.3 mi E of site in Talking Rock Creek 

US Percina jenkinsi (Conasauga Logperch) approx. 2.3 mi NE of site in the Conasauga River

GA Percina kusha (Bridled Darter) approx. 0.1 mi NE of site in the Conasauga River

GA Percina lenticula (Freckled Darter) in an uncertain location near the project site in 

Coahulla Creek

GA Percina lenticula (Freckled Darter) approx. 1.1 mi SW of site in the Coosawattee River

GA Percina lenticula (Freckled Darter) approx. 0.3 mi N of site in the Conasauga River

Percina sciera (Dusky Darter) approx. 2.7 mi S of site in Tiger Creek

US Percina tanasi (Snail Darter) on site in South Chickamauga Creek

Perimyotis subflavus (Tri-colored Bat) approx. 0.1 mi S of site 

Perimyotis subflavus (Tri-colored Bat) approx. 1.3 mi W of site 

Perimyotis subflavus (Tri-colored Bat) [HISTORIC] approx. 2.2 mi SW of site 

Perimyotis subflavus (Tri-colored Bat) [HISTORIC] in an uncertain location near the 

project site 

Perimyotis subflavus (Tri-colored Bat) [HISTORIC] approx. 1.3 mi N of site 

Phacelia fimbriata (Fringed Phacelia) approx. 0.1 mi E of site 

GA Phenacobius uranops (Stargazing Minnow) approx. 2.3 mi S of site in Tiger Creek

GA Phenacobius uranops (Stargazing Minnow) on site in South Chickamauga Creek

GA Phenacobius uranops (Stargazing Minnow) approx. 0.3 mi S of site in South 

Chickamauga Creek

US Pleurobema decisum (Southern Clubshell) approx. 0.1 mi NE of site in Conasauga River

US Pleurobema decisum (Southern Clubshell) [HISTORIC] on site in Coahulla Creek

US Pleurobema decisum (Southern Clubshell) [HISTORIC] approx. 1.9 mi SW of site in the 

Coosawattee River

US Pleurobema decisum (Southern Clubshell) [HISTORIC] approx. 2.0 mi S of site in Holly 

Creek 
IR 16742

US Pleurobema georgianum (Southern Pigtoe) approx. 3.0 mi E of site in the Conasauga 

River

US Pleurobema hanleyianum (Georgia Pigtoe) approx. 2.3 mi E of site in the Conasauga 

River

Pleurocera pyrenella (Skirted Hornsnail) [HISTORIC?] approx. 1.0 mi SW of site in 

Peavine Creek

Pleuronaia barnesiana (Tennessee Pigtoe) approx. 2.5 mi S of site in Tiger Creek 

Polemonium reptans (Jacobs Ladder) [HISTORIC] approx. 2.3 mi NW of site 

Pseudacris brachyphona (Mountain Chorus Frog) approx. 2.5 mi W of site 

Pseudacris brachyphona (Mountain Chorus Frog) approx. 2.1 mi SE of site 

US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 0.1 mi NE of site in the 

Conasauga River

US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 1.6 mi S of site in Holly 

Creek

US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 2.3 mi SW of site in Little 

Creek

Quadrula asperata (Alabama Orb) approx. 2.3 mi NE of site in the Conasauga River

Quadrula asperata (Alabama Orb) approx. 1.9 mi SW of site in the Coosawattee River

Quadrula rumphiana (Ridged Mapleleaf) approx. 1.1 mi E of site in the Conasauga River

Ribes curvatum (Granite Gooseberry) approx. 2.0 mi NE of site 

GA Sabatia capitata (Cumberland Rose-gentian) in an uncertain location near the project site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.2 mi SE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 0.9 mi SE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.9 mi E of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.5 mi E of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.4 mi W of site 

GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] approx. 1.7 mi S of site 

GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] approx. 0.3 mi SE of site 

GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC] approx. 2.2 mi E of site 

GA Sabatia capitata (Cumberland Rose-gentian) [HISTORIC?] approx. 1.6 mi SE of site 

US Scutellaria montana (Large-flowered Skullcap) in an uncertain location near the project 

site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.1 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.9 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.8 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.3 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.5 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.2 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.4 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi N of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.8 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.9 mi S of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.6 mi SW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.0 mi SW of site 
IR 16742

US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi N of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.1 mi S of site 

GA Strophitus connasaugaensis (Alabama Creekmussel) approx. 1.3 mi W of site in Rock 

Creek

GA Strophitus connasaugaensis (Alabama Creekmussel) approx. 2.5 mi E of site in the 

Conasauga River

GA Strophitus connasaugaensis (Alabama Creekmussel) approx. 2.4 mi N of site in Holly 

Creek

US Symphyotrichum georgianum (Georgia Aster) approx. 0.2 mi NW of site 

US Symphyotrichum georgianum (Georgia Aster) approx. 2.7 mi E of site 

US Symphyotrichum georgianum (Georgia Aster) approx. 0.8 mi W of site 

US Symphyotrichum georgianum (Georgia Aster) approx. 1.8 mi W of site 

US Symphyotrichum georgianum (Georgia Aster) in an uncertain location near the project site 

US Symphyotrichum georgianum (Georgia Aster) [EXTIRPATED?] approx. 2.6 mi E of site 

Symphyotrichum novae-angliae (New England Aster) approx. 0.7 mi W of site 

Thryomanes bewickii (Bewick's Wren) approx. 1.7 mi SW of site 

Trillium lancifolium (Lanceleaf Trillium) approx. 2.5 mi SW of site 

Trillium lancifolium (Lanceleaf Trillium) [HISTORIC] approx. 0.3 mi E of site 

Villosa nebulosa (Alabama Rainbow) approx. 0.8 mi SW of site in Pitner Branch

Villosa nebulosa (Alabama Rainbow) approx. 0.3 mi W of site in Rock Creek

Villosa nebulosa (Alabama Rainbow) approx. 2.3 mi NE of site in the Conasauga River

Villosa trabalis (Cumberland Bean) [EXTIRPATED] approx. 1.8 mi SW of site 

Villosa umbrans (Coosa Creekshell) approx. 0.8 mi SW of site in Pitner Branch

Villosa umbrans (Coosa Creekshell) in an uncertain location near the project site in Rock 

Creek

Villosa umbrans (Coosa Creekshell) on site in an Unnamed Tributary to Sugar Creek

Villosa umbrans (Coosa Creekshell) [HISTORIC?] approx. 0.4 mi NE of site in Wilson 

Creek

Villosa vanuxemensis (Mountain Creekshell) approx. 0.9 mi S of site in Tiger Creek

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 0.6 mi W of site 

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) in an uncertain location near the 

project site

Bartow County Greenspace approx. 2.7 mi E of site 

Bartow County Greenspace approx. 2.9 mi E of site 

Catoosa County Greenspace approx. 1.6 mi SW of site 

Catoosa County Greenspace approx. 1.9 mi SW of site 

Catoosa County Greenspace approx. 2.2 mi SW of site 

Catoosa County Greenspace approx. 2.4 mi SW of site 

Catoosa County Greenspace approx. 2.9 mi SW of site 

Catoosa County Greenspace on site 

Cherokee County Greenspace approx. 2.7 mi E of site 

Cherokee County Greenspace approx. 2.9 mi E of site 

Cumberland Plateau/ridge and Valley Cave on site 

Forest, sagpond (Sagpond Forest) approx. 3.0 mi N of site 

Mountain spring (Mountain Spring) 1.9 mi N of site 

Murray County Greenspace approx. 2.2 mi N of site 
IR 16742

Pinus palustris - Pinus echinata - (Pinus virginiana) / Quercus marilandica - (Quercus 

prinus) / Vaccinium pallidum Woodland (Montane Mixed Longleaf Woodland) A, 

approx. 1.9 mi SE of site 

Anthony's Cave approx. 2.5 mi W of site 

Apple Cave approx. 2.7 mi NE of site 

Arnold Cave approx. 1.0 mi W of site 

Baxter Cave approx. 0.5 mi E of site 

Bradford Cave approx. 0.1 mi E of site 

Cactus Cave approx. 2.6 mi N of site 

Callaway Cave approx. 0.2 mi NE of site 

Cave Hill Cave approx. 0.6 mi N of site 

Cedar Ridge #1 [Cave] on site 

Cedar Ridge #2 [Cave] on site 

Cedar Ridge #3 [Cave] on site 

Chapman's Cave approx. 2.3 mi SW of site 

Chickamauga Cave approx. 0.8 mi SW of site 

Fallen Oak Sink [Cave] approx. 0.6 mi S of site 

Fincher Bluff Cave approx. 0.6 mi S of site 

Goodson Bend #1 [Cave] approx. 1.3 mi SW of site 

Goodson Bend #2 [Cave] approx. 1.3 mi SW of site 

Hesitation Hole [Cave], on site 

Howard Hughes Cave approx. 0.8 mi S of site 

Impressive Fern Pud [Cave], approx. 0.8 mi SW of site 

Jack Crider Cave approx. 2.0 mi NW of site 

Jonboat Cave approx. 1.7 mi SW of site 

Ketchum's Cave on site 

Long's Short Cave approx. 2.3 mi W of site 

Lost Creek Cave approx. 0.8 mi SW of site 

Lost Creek Cave approx. 1.0 mi SW of site 

Major Pullim's Cave approx. 0.7 mi SW of site 

Mayben Cave approx. 0.1 mi W of site 

McKinney Spring [Cave] approx. 0.3 mi NE of site 

Preacher Sluder Cave approx. 1.0 mi E of site 

Rusty Cable Cave approx. 2.2 mi NW of site 

Sonoraville Cave approx. 1.3 mi W of site 

Spider Cave approx. 0.4 mi E of site 

Steep Cave approx. 2.2 mi NW of site 

Trestle Cave on site 

Whiteoak Mtn Cave approx. 2.5 mi S of site 

Conasauga River 2 (0315010102) [SWAP High Priority Watershed] on site 

Coahulla Creek (0315010103) [SWAP High Priority Watershed] on site 

Holly Creek (0315010104) [SWAP High Priority Watershed] on site 

Conasauga River 1 (0315010105) [SWAP High Priority Watershed] on site 

Coosawatee River 2, Carters Lake (0315010204) [SWAP High Priority Watershed] 

approx. 1.1 mi E of site 

Talking Rock Creek (0315010205) [SWAP High Priority Watershed] on site 
IR 16742

Salacoa Creek (0315010206) [SWAP High Priority Watershed] on site 

Coosawatee River 1 (0315010208) [SWAP High Priority Watershed] on site 

Etowah River 4, Allatoona Lake (0315010410) [SWAP High Priority Watershed] on site 

Pumpkinvine Creek (0315010411) [SWAP High Priority Watershed] approx. 2.4 mi S of 

site 

Etowah River 2 (0315010415) [SWAP High Priority Watershed] approx. 2.1 mi NW of 

site 

Little Chickamauga Creek (0602000109) [SWAP High Priority Watershed] on site

Chickamauga Creek (0602000108) [SWAP High Priority Watershed] on site

Rome Loop (Site Center: -85.109874, 34.306668, WGS84)

Acipenser fulvescens (Lake Sturgeon) approx. 0.6 mi NE of site in the Etowah River

Amblema elliottii (Coosa Fiveridge) approx. 1.9 mi NW of site in the Oostanaula River

Amblema elliottii (Coosa Fiveridge) approx. 2.5 mi N of site in the Oostanaula River

US Arabis georgiana (Georgia Rockcress) approx. 0.4 mi NW of site 

Asclepias hirtella (Barrens Milkweed) approx. 2.0 mi NW of site 

Camassia scilloides (Wild Hyacinth) approx. 1.3 mi NW of site 

GA Cambarus fasciatus (Etowah Crayfish) approx. 2.9 mi N of site in Tom’s Creek

Carex eburnea (Black-seed Sedge) approx. 1.7 mi NW of site 

Carex purpurifera (Purple Sedge) approx. 0.5 mi NW of site 

Carex purpurifera (Purple Sedge) approx. 1.7 mi NW of site 

Chaerophyllum procumbens (Spreading Chervil) approx. 1.8 mi NW of site 

Cheilanthes alabamensis (Alabama Lipfern) approx. 2.3 mi SE of site 

Cheilanthes alabamensis (Alabama Lipfern) approx. 1.5 mi SE of site 

GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.3 mi NW of site 

GA Crataegus triflora (Three-flowered Hawthorn) approx. 1.8 mi NW of site 

GA Crataegus triflora (Three-flowered Hawthorn) approx. 0.5 mi NW of site 

GA Cypripedium acaule (Pink Ladyslipper) approx. 2.4 mi NE of site 

GA Elliptio arca (Alabama Spike) approx. 1.8 mi NW of site in the Oostanaula River

US Epioblasma penita (Southern Combshell) [HISTORIC?] approx. 2.3 mi NW of site in the 

Oostanaula River

GA Etheostoma ditrema (Coldwater Darter) approx. 2.7 mi S of site in an Unnamed Tributary 

to Oothkalooga Creek

GA Etheostoma ditrema (Coldwater Darter) approx. 1.2 mi NW of site in an Unnamed 

Tributary to Woodward Creek

US Etheostoma etowahae (Etowah Darter) approx. 1.0 mi S of site in the Etowah River

US Etheostoma scotti (Cherokee Darter) in an uncertain location near the project site in Nancy 

Creek and Unnamed Tributaries

US Etheostoma scotti (Cherokee Darter) approx. 1.1 mi NE of site in Pettit Creek and 

Unnamed Tributaries

GA Etheostoma trisella (Trispot Darter) approx. 1.3 mi NW of site in Woodward Creek

GA Gomphus consanguis (Cherokee Clubtail) approx. 2.5 mi N of site in Robbins Creek

GA Gomphus consanguis (Cherokee Clubtail) approx. 0.1 mi SE of site in Woodward Creek

GA Haliaeetus leucocephalus (Bald Eagle) approx. 2.3 mi S of site 

Hiodon tergisus (Mooneye) approx. 0.5 mi NW of site in the Oostanaula River
IR 16742

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 0.3 mi SE of site in the 

Oostanaula River

GA Hybopsis lineapunctata (Lined Chub) [HISTORIC] approx. 0.6 mi NW of site in Lynn 

Creek

Hybopsis sp. 9 (Etowah Chub) [HISTORIC] approx. 2.0 mi E of site in Dyke’s Creek

Lampropeltis triangulum triangulum (Eastern Milk Snake) approx. 2.5 mi W of site 

Lampsilis straminea (Southern Fatmucket) approx. 3.0 mi E of site in Dykes Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 2.7 mi SW of site in Shoal Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 0.1 mi N of site in Nancy Creek

Lasmigona etowaensis (Etowah Heelsplitter) approx. 2.0 mi NE of site in Pettit Creek

US Leptoxis foremani (Interrupted Rocksnail) approx. 1.8 mi NW of site in the Oostanaula 

River

US Lioplax cyclostomaformis (Cylindrical Lioplax) [HISTORIC] in an uncertain location near 

the project site in the Oostanaula River

Lythrurus lirus (Mountain Shiner) approx. 2.2 mi N of site in Robbins Creek

Lythrurus lirus (Mountain Shiner) approx. 2.2 mi N of site in Robbins Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.6 mi NW of site in Lynn Creek

Lythrurus lirus (Mountain Shiner) [HISTORIC] approx. 0.3 mi N of site in the Etowah 

River

Macrhybopsis storeriana (Silver Chub) approx. 1.9 mi NW of site in the Oostanaula River

Macrhybopsis storeriana (Silver Chub) approx. 2.7 mi W of site in the Oostanaula River

Macrhybopsis storeriana (Silver Chub) approx. 1.9 mi NW of site in the Oostanaula River

US Marshallia mohrii (Coosa Barbara Buttons) approx. 2.0 mi NW of site 

US Medionidus acutissimus (Alabama Moccasinshell) [HISTORIC] on site in Ookalooga 

Creek

GA Moxostoma carinatum (River Redhorse) approx. 1.9 mi NW of site in Armuchee Creek

GA Moxostoma carinatum (River Redhorse) approx. 0.5 mi NW of site in the Oostanaula 

River

US Myotis grisescens (Gray Myotis) approx. 1.6 mi NW of site 

Myotis lucifugus (Little Brown Myotis) approx. 0.9 mi S of site 

US Myotis septentrionalis (Northern Myotis) approx. 0.9 mi S of site 

GA Pachysandra procumbens (Allegheny-spurge) approx. 0.4 mi NW of site 

Panax quinquefolius (American Ginseng) approx. 1.6 mi NW of site 

Panax quinquefolius (American Ginseng) approx. 1.7 mi NW of site 

Perimyotis subflavus (Tri-colored Bat) approx. 2.7 mi S of site 

Perimyotis subflavus (Tri-colored Bat) approx. 2.3 mi NE of site 

Perimyotis subflavus (Tri-colored Bat) approx. 0.9 mi S of site 

Perimyotis subflavus (Tri-colored Bat) approx. 0.3 mi N of site 

Pituophis melanoleucus melanoleucus (Northern Pine Snake) approx. 0.7 mi S of site 

US Pleurobema decisum (Southern Clubshell) [EXTIRPATED?] approx. 1.9 mi NW of site in 

the Oostanaula River

Pleurocera showalteri (Upland Hornsnail) approx. 1.7 mi NW of site in the Oostanaula 

River

Polemonium reptans (Jacobs Ladder) approx. 1.7 mi NW of site 

Potamogeton amplifolius (Bigleaf Pondweed) [HISTORIC] in an uncertain location near 

the project site 
IR 16742

US Ptychobranchus foremanianus (Rayed Kidneyshell) approx. 1.0 mi NW of site in the 

Oostanaula River

Quadrula asperata (Alabama Orb) approx. 1.5 mi NW of site in the Oostanaula River

Quadrula asperata (Alabama Orb) approx. 2.6 mi N of site in the Oostanaula River

Quadrula rumphiana (Ridged Mapleleaf) approx. 1.9 mi NW of site in the Oostanaula 

River

Quadrula rumphiana (Ridged Mapleleaf) approx. 2.5 mi N of site in the Oostanaula River

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.2 mi N of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 1.0 mi SE of site 

GA Sabatia capitata (Cumberland Rose-gentian) approx. 2.0 mi NE of site 

GA Schisandra glabra (Bay Star-vine) approx. 1.7 mi SE of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.4 mi NW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.5 mi NW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.6 mi NW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 2.1 mi N of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.8 mi NW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 0.3 mi NW of site 

US Scutellaria montana (Large-flowered Skullcap) approx. 1.3 mi NW of site 

US Scutellaria montana (Large-flowered Skullcap) [EXTIRPATED] approx. 1.4 mi NW of 

site 

Scutellaria nervosa (Bottomland Skullcap) approx. 0.5 mi NW of site 

GA Silene regia (Royal Catchfly) [HISTORIC] approx. 1.3 mi NW of site 

GA Symphyotrichum georgianum (Georgia Aster) approx. 1.3 mi NE of site 

Tyto alba (Barn owl) in an uncertain location near the project site 

Villosa umbrans (Coosa Creekshell) approx. 1.0 mi N of site in Two Run Creek

Villosa umbrans (Coosa Creekshell) approx. 2.8 mi N of site in an Unnamed Tributary to 

Oothkalooga Creek

Villosa umbrans (Coosa Creekshell) approx. 2.1 mi E of site in Dykes Creek

Villosa umbrans (Coosa Creekshell) approx. 1.8 mi NW of site in the Oostanaula River

US Xyris tennesseensis (Tennessee Yellow-eyed Grass) approx. 1.8 mi E of site 

Bartow County Greenspace approx. 2.6 mi N of site 

Floyd County Greenspace approx. 2.6 mi W of site 

Braden's Cave approx. 0.5 mi N of site 

Celanese Cave approx. 1.7 mi W of site 

Charles Floyd's Cave approx. 0.9 mi N of site 

Jolley Cave approx. 0.8 mi N of site 

Kingston Corner Cave approx. 1.9 mi N of site 

Kingston Saltpeter Cave approx. 0.9 mi S of site 

Lumpkin's Crawl [Cave], approx. 1.4 mi NW of site 

Manis Cave approx. 1.6 mi SE of site 

Mo Hole [Cave], approx. 2.6 mi SE of site 

North Cat Den Cave approx. 2.0 mi SE of site 

Plainville Cave approx. 0.5 mi NW of site 

Quarles Bluff #1 [Cave], approx. 0.6 mi NW of site 

Quarles Bluff #2 [Cave], approx. 0.5 mi NW of site 

Self Cave approx. 0.9 mi S of site 
IR 16742

South Cat Den Cave approx. 2.0 mi SE of site 

Yarbrough Cave approx. 2.4 mi SE of site 

Oostanaula River 2 (0315010301) [SWAP High Priority Watershed] on site 

Oothkalooga Creek (0315010302) [SWAP High Priority Watershed] on site 

Armuchee Creek (0315010305) [SWAP High Priority Watershed] approx. 2.0 mi NW of 

site 

Allatoona Creek, Allatoona Lake (0315010409) [SWAP High Priority Watershed] approx. 

2.0 mi SE of site 

Pumpkinvine Creek (0315010411) [SWAP High Priority Watershed] approx. 2.4 mi S of 

site 

Etowah River 3 (0315010413) [SWAP High Priority Watershed] on site 

Etowah River 2 (0315010415) [SWAP High Priority Watershed] on site

Recommendations: 

The Atlanta-Chattanooga High Speed Ground Transportation Project (PI: T001684) traverses 

many different habitat types. According to our records, several high priority species and 

communities have potential to be impacted by construction. We have included in this response a 

list of documented occurrences within three miles of the three proposed alternative routes. 

To minimize potential impacts to federally listed species, we recommend consultation with the 

United States Fish and Wildlife Service. In North Georgia, please contact Robin Goodloe (706-

613-9493, ext.221 or Robin_Goodloe@fws.gov). 

There are several state-protected species that have potential to be affected by the proposed 

construction. Please contact these biologists for recommendations/ assistance regarding the 

following taxonomic groups: 

Plants: Tom Patrick (Tom.Patrick@dnr.ga.gov); 

Fish & Crayfish: Brett Albanese (Brett.Albanese@dnr.ga.gov ); 

Mussels: Jason Wisniewski (Jason.Wisniewski@dnr.ga.gov ); 

Reptiles & Amphibians: John Jensen (John.Jensen@dnr.ga.gov ); 

Mammals: Trina Morris (Katrina.Morris@dnr.ga.gov); 

Birds: Nathan Klaus (Nathan.Klaus@dnr.state.ga.us). 

Once the preferred route has been established, our biologists can meet with project consultants to 

discuss survey needs for species of conservation concern and methods to minimize or mitigate 

impacts to these species.

The proposed rail will transect several high priority watersheds identified in the State Wildlife 

Action Plan. Please refer to Appendix F of Georgia’s State Wildlife Action Plan to find out 

more specific information about these watersheds. (http://www.georgiawildlife.org/SWAP2015).
IR 16742

Disclaimer: 

Please keep in mind the limitations of our database. The data collected by the Nongame 

Conservation Section comes from a variety of sources, including museum and herbarium 

records, literature, and reports from individuals and organizations, as well as field surveys by our 

staff biologists. In most cases the information is not the result of a recent on-site survey by our 

staff. Many areas of Georgia have never been surveyed thoroughly. Therefore, the Nongame 

Conservation Section can only occasionally provide definitive information on the presence or 

absence of rare species on a given site. Our files are updated constantly as new information is 

received. Thus, information provided by our program represents the existing data in our 

files at the time of the request and should not be considered a final statement on the species 

or area under consideration.

If you know of populations of highest priority species that are not in our database, please fill out 

the appropriate data collection form and send it to our office. Forms can be obtained through our 

web site (http://www.georgiawildlife.com/node/1376) or by contacting our office. If I can be of 

further assistance, please let me know. 

Sincerely,

Anna Yellin

Environmental Review Coordinator

Data Available on the Nongame Conservation Section Website

 Georgia protected plant and animal profiles are available on our website. These accounts cover basics like 

descriptions and life history, as well as threats, management recommendations and conservation status. 

Visit http://www.georgiawildlife.com/node/2721.

 Rare species and natural community information can be viewed by Quarter Quad, County and HUC8 

Watershed. To access this information, please visit our GA Rare Species and Natural Community 

Information page at: http://www.georgiawildlife.com/conservation/species-of-concern?cat=conservation.

 Downloadable files of rare species and natural community data by quarter quad and county are also 

available. They can be downloaded from: http://www.georgiawildlife.com/node/1370.
1

Smart, Brian

From: Heckler, Ariel L <AHeckler@dot.ga.gov>

Sent: Friday, November 18, 2016 11:42 AM

To: Smart, Brian

Subject: FW: Atlanta to Chattanooga Teir 1 EIS Question

Another comment. Thanks, Ariel

From: Wallace, Dan - NRCS, Athens, GA [mailto:Dan.Wallace@ga.usda.gov]

Sent: Wednesday, November 16, 2016 5:13 PM

To: Heckler, Ariel L

Subject: Atlanta to Chattanooga Teir 1 EIS Question

Hello, I am preparing a respond from NRCS to the Oct. 21 notification of the Teir 1 Draft EIS. One of NRCS’s statutory responsibilities is the Farmland Protection

Policy Act (FPPA). I have prepared some responses to the HSGT over the years that pointed out the necessity of this project going through the FPPA process. I

don’t see anything in the draft EIS addressing FPPA. But it’s a very big document. Are you familiar with the details, and, if so, do you know of sections of the EIS

addressing FPPA? The act is an effort to stop federal funds irreversibly converting the nation’s farmland out of farmable use. It relies on identifying soils rated as

prime farmland and assessing for the least converting alternative.

It’s no big deal if it’s not there, I’ll just prepare the response pointing out that FPPA consultation is necessary. But, if it’s there, I’d like to prepare the response

accordingly. Thank you, Dan

Daniel F. Wallace

USDA NRCS Georgia Resource Inventory Coordinator

355 E. Hancock Ave.

Athens, GA 30601

(706) 546-2244

www.nrcs.usda.gov

www.ga.nrcs.usda.gov

www.soils.usda.gov
2

This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this

message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you

believe you have received this message in error, please notify the sender and delete the email immediately.

Pedestrian deaths are surging in Georgia - 206 people were killed while walking in 2015. With pedestrian deaths up 37% in two years, Georgia DOT’s SEE &

BE SEEN campaign, in partnership with PEDS, aims to make it safer to walk in Georgia. Safety is a shared responsibility. Walkers and drivers: Pay attention.

Walkers: make sure you can SEE & BE SEEN. Drivers: Slow down (speed kills). Visit www.dot.ga.gov/DS/SafetyOperation/SBS. #ArriveAliveGA
STATE OF TENNESSEE

DEPARTMENT OF ENVIRONMENT AND CONSERVATION

NASHVILLE, TENNESSEE 37243-0435

ROBERT J. MARTINEAU, JR. BILL HASLAM

COMMISSIONER GOVERNOR

November 18, 2016

Via Electronic Mail to AtlChatt@dot.ga.gov

Attn: Ariel Heckler, Project Manager

Division of Intermodal

Georgia Department of Transportation

One Georgia Center – 600 West Peachtree NW

Atlanta, GA 30308

Dear Ms. Heckler:

The Tennessee Department of Environment and Conservation (TDEC) appreciates the opportunity to provide 

comments on the Federal Railroad Administration (FRA), Georgia Department of Transportation (GDOT), and 

Tennessee Department of Transportation (TDOT) Atlanta-Chattanooga High Speed Ground Transportation Project 

Tier I Draft Environmental Impact Statement (Draft EIS). The FRA, in cooperation with GDOT and TDOT, 

proposes to construct a high-speed intercity passenger service connecting Atlanta, Georgia and Chattanooga, 

Tennessee. The project aims to enhance intercity mobility and economic growth throughout the project area 

between the metropolitan areas and the airports of Atlanta and Chattanooga by providing faster and more reliable 

ground transportation service to the public as an alternative to highway, intercity bus, and air travel in a manner that 

is safe and cost-effective, while avoiding, minimizing, and mitigating impacts on the human and natural 

environment. 

Actions considered in detail within the Draft EIS include: 

 No-Build Alternative – Under the No-Build Alternative, the FRA, GDOT, and TDOT would take no action 

to construct a high-speed ground transportation (HSGT) project in the project area. Existing transportation 

systems would remain in place, and all transportation system improvements that are currently listed in local, 

regional, and state transportation plans that have identified funds for implementation will be implemented.

 I-75 Corridor Alternative – Under the I-75 Corridor Alternative, the HSGT project would begin on the east 

side of Hartsfield-Jackson Atlanta International Airport immediately adjacent to I-75, following I-75 north 

along the I-75 right-of-way (ROW). North of I-24 in Tennessee, the corridor continues along an existing 

CSX rail ROW to downtown Chattanooga.

 East Corridor Alternative – Under the East Corridor Alternative, the HSGT project would follow the same 

alignment as the I-75 corridor until Cartersville, where it would deviate from I-75 and continue along 

existing CSX ROW parallel to US 411 and into Chattanooga.

 I-75/East Corridor Alternative – Under the I-75/East Corridor Alternative, the HSGT project would follow 

the same path as the I-75 and East corridors to Cartersville and follow US 411 to Rome, where it would 
continue along an existing CSX ROW to rejoin I-75 between Cartersville and Dalton. The corridor would 

continue along the I-75 ROW to Dalton and into downtown Chattanooga.

TDEC’s Office of Energy Programs and the Tennessee Geological Survey (TGS) have reviewed the Draft EIS

and have no specific comments regarding the proposed action or its alternatives.

TDEC’s Tennessee State Parks and Real Property Management have reviewed the Draft EIS and note that the 

proposed project should not impact TDEC managed lands.

TDEC’s Division of Archaeology (DoA) has reviewed the Draft EIS and provides the following comments 

regarding the proposed action alternatives that occur within Tennessee. TDOT archaeologists have identified all 

properties in the study area that are listed or potentially eligible for listing in the National Register of Historic Places 

(3.8.4.2). DoA notes that other potentially significant sites may exist and have yet to be identified, which will be 

determined by TDOT as part of their responsibilities to comply with Section 106 (3.8.6). At this time, DoA concurs

with TDOT findings and suggestions related to this project as discussed within the Draft EIS.

TDEC’s Division of Natural Areas (DNA) has reviewed the Draft EIS and provides the following comments 

regarding the proposed action alternatives that occur within Tennessee. For areas of the project occurring in 

Hamilton County, Tennessee, DNA prefers for the project to use an existing corridor when possible. Besides the 

known occurrences of rare species included in the NEPA document for Hamilton County, there could be additional 

rare species that DNA is unaware of because not all of Tennessee has been surveyed. Should suitable habitat for 

rare species existing on or immediately downstream of the project site, DNA recommends that the project plans 

provide for the protection of these species. For stabilization of disturbed areas, the Tennessee Natural Heritage 

Program advocates the use of native trees, shrubs, and warm season grasses, where practicable. Care should be 

taken to prevent re-vegetation of disturbed areas with plants listed by the Tennessee Exotic Pest Plan Council as 

harmful exotic plants.1

TDEC’s Division of Air Pollution Control (APC) has reviewed the Draft EIS and provides the following 

comments regarding the proposed action alternatives that occur within Tennessee.

 Dust emissions generated by construction activities can vary substantially depending on levels of activity, 

specific operations, and prevailing meteorological conditions. However, dust emissions due to construction 

activities are likely to be short-term and temporary in nature. It is recommended that ordinary dust control 

measures, such as wetting by water spray, be employed to mitigate any dust emissions generated. APC 

recommends that mitigation of dust emissions be addressed in future National Environmental Policy Act 

(NEPA) documents related to this project.

 Exhaust emissions generated by onsite construction equipment are not likely to be of concern during the 

project. However, APC recommends that mitigation of exhaust emissions be addressed in future NEPA 

documents related to this project.

 The proposed project does not reference demolition of buildings. However, if demolition is to occur, 

fugitive dust emissions produced may require mitigation. Demolition would also require an asbestos 

demolition notification in advance of any activity as well as proper pre-demolition surveys to identify any 

regulated asbestos-containing materials (ACM) that may be present. Should any ACM be present, it would 

need to be handled and disposed of according to applicable Federal, state, and local regulations. This should 

be addressed in future NEPA documents.

 Should any land clearing activities or disposal of brush or trees/tree limbs occur, APC prefers that wood 

waste be disposed of by chipping, grinding, or composting rather than open burning. However, if open 

 

1 Additional information regarding harmful exotic plants in Tennessee can be found at http://www.tneppc.org/. 
burning does occur during site preparation and construction, open burning regulations should be followed.2

APC recommends that detailed clearing activities, total amount of areas where soils are to be disturbed, and 

associated impacts be addressed in future NEPA documents related to this project.

 The National Ambient Air Quality Standards (NAAQS) table (Table 3.6) provided does not include the 

revised ozone standard of 0.070 ppm.3

 Page 3-20 indicates that TDEC APC is responsible for monitoring and enforcing air quality regulations in 

the State of Tennessee. While this statement is correct, in the case of Hamilton County, the 

Chattanooga/Hamilton County Air Pollution Control Bureau has been delegated authority to monitor air 

quality and has jurisdiction over air quality issues within the county. This should be reflected in future 

NEPA documents related to this project.

 Page 3-21 of the Draft EIS notes that Chattanooga is classified as a Non-Attainment Area for the 1997 

PM2.5 Annual Standard. Chattanooga is actually classified as attaining the 1997 2.5 Annual Standard. It is 

recommended that this be reflected in future NEPA documents related to this project.

 Data contained within Table 3-7 for Hamilton County should be updated to reflect the 2014, 2015, and 

possibly 2016 data for Chattanooga rather than 2012 and 2013 data.

TDEC’s Division of Water Resources (DWR) has reviewed the Draft EIS and provides the following comments 

regarding the proposed action alternatives that occur within Tennessee. As is typical with long range transportation 

planning and project execution, specific project details associated with each alternative are still being determined. 

DWR looks forward to working with TDOT, GDOT, and FRA as this project develops.

 The Tennessee portion of the project will likely required an Aquatic Resource Alteration Permit for stream 

crossings, wetlands, etc., as well as a construction stormwater permit due to the large area being disturbed 

exceeding one acre. 

 Construction activities, including clearing, grading, filling, and excavating, or other similar activities, 

including staging areas, that result in the disturbance of one acre or more of total land area require coverage 

under Tennessee’s General National Pollutant Discharge Elimination System (NPDES) permit for 

discharges of stormwater associated with construction activities. 

 Given the karst geology of the area, a letter of authorization from DWR’s Underground Injection Control 

program for sinkhole modification will likely be required as well. 

TDEC appreciates the opportunity to comment on this Draft EIS. Please note that these comments are not indicative 

of approval or disapproval of the proposed action or its alternatives, nor should they be interpreted as an indication 

regarding future permitting decisions by TDEC. Please contact me should you have any questions regarding these 

comments.

Sincerely, 

Kendra Abkowitz, PhD

Director of Policy and Planning

Tennessee Department of Environment and Conservation

Kendra.Abkowitz@tn.gov

 

2 TDEC APC Rule 1200-3-4-.01 et seq., http://share.tn.gov/sos/rules/1200/1200-03/1200-03-04.pdf. Additional information on 

open burning in Tennessee is available at https://tn.gov/environment/article/apc-open-burning and http://www.burnsafetn.org/. 

3 The current EPA NAAQS table is available at https://www.epa.gov/criteria-air-pollutants/naaqs-table. The final rule was 

signed October 1, 2015 and became effective December 28, 2015.
(615) 532-8689

cc: Molly Cripps, TDEC, OEP

Ron Zurawski, TDEC, TGS

Mark Norton, TDEC, DoA

Stephanie A. Williams, TDEC, DNA

Lacey Hardin, TDEC, APC

Tom Moss, TDEC, DWR

Bill Avant, TDEC, TSP

1

Smart, Brian

From: Heckler, Ariel L <AHeckler@dot.ga.gov> on behalf of AtlChatt <AtlChatt@dot.ga.gov>

Sent: Wednesday, November 23, 2016 10:32 AM

To: Smart, Brian

Subject: FW: Tier 1 DEIS for the Atlanta to Chattanooga High Speed Ground Transporation Project

From: karen pritchett [mailto:kpritchett@ukb-nsn.gov]

Sent: Monday, November 21, 2016 4:08 PM

To: AtlChatt

Cc: jennifer.bedell@dnr.ga.gov; Jennifer.Barnett@tn.gov; Eric Oosahwee; karen pritchett

Subject: Tier 1 DEIS for the Atlanta to Chattanooga High Speed Ground Transporation Project

Dear GDOT,

On behalf of Tribal Historic Preservation Officer (THPO) Eric Oosahwee-Voss, please accept this digital communication regarding the Tier 1 DEIS for the Atlanta to

Chattanooga High Speed Ground Transportation Project.

Please be advised that the proposed undertaking lies within the traditional territory of the United Keetoowah Band of Cherokee Indians in Oklahoma (UKB). This

opinion is being provided by UKB THPO, pursuant to authority vested by the UKB Corporate Board and under resolution 16-UKB-34. The United Keetoowah Band

is a Federally Recognized Indian Nation headquartered in Tahlequah, OK.

Our preferred alternative is the I-75 corridor, however, please note that whatever corridor is chosen, we want a full cultural resources study prior to project

implementation. Thank you for consulting with the UKB. Please note that these comments are based on information available to us at the time of the project

review. We reserve the right to revise our comments as information becomes available. If you have any questions or concerns, please contact me at (918) 458-

6715 or kpritchett@ukb-nsn.gov or THPO Eric Oosahwee-Voss at (918) 458-6717 or eoosahwee-voss@ukb-nsn.gov

Thank you,

Karen Pritchett

THPO Assistant

Tribal Historic Preservation Office

United Keetoowah Band of Cherokee Indians in Oklahoma

P. O. Box 1245

UKB# U16-945

16.0973
2

Tahlequah, OK 74465

918-458-6715

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BE SEEN campaign, in partnership with PEDS, aims to make it safer to walk in Georgia. Safety is a shared responsibility. Walkers and drivers: Pay attention.

Walkers: make sure you can SEE & BE SEEN. Drivers: Slow down (speed kills). Visit www.dot.ga.gov/DS/SafetyOperation/SBS. #ArriveAliveGA
[Type here]

1

United States Department of the Interior

OFFICE OF THE SECRETARY

Office of Environmental Policy and Compliance

Richard B. Russell Federal Building

75 Ted Turner Drive, S.W., Suite 1144

Atlanta, Georgia 30303

ER 16/0572

9043.1

November 21, 2016

Mr. John Winkle

Office of Railroad Policy and Development

Federal Railroad Administration

1200 New Jersey Avenue SE, MS-20

Washington, DC 20590

Re: Comments and Recommendations on the Tier 1 Draft Environmental Impact Statement 

(EIS) for the Atlanta-Chattanooga High Speed Ground Transportation Project

Dear Mr. Winkle:

The U.S. Department of the Interior (Department) has reviewed the Tier 1 Draft Environmental 

Impact Statement (EIS) for the Atlanta-Chattanooga High Speed Ground Transportation Project. 

We offer the following comments for your consideration:

Section 4(f) and Section 6(f) Resources

The Tier 1 Draft EIS combines the U.S. Department of Transportation (USDOT) Act Section 

4(f) and the Land and Water Conservation Fund (LWCF) Act Section 6(f) analysis under a joint 

discussion throughout the document. The Draft EIS provides sufficient Tier 1 preliminary detail 

that addresses the requirements of the Section 4(f) and the LWCF Section 6(f) processes.

As noted in the Tier 1 Draft EIS, the analysis contained within the document focuses on the 

broader land use implications of the alternatives on a conceptual corridor level. Specific 

alignments and associated resource identification are deferred until the Tier 2 EIS phase. As a 

result, the Department will defer Section 4(f) and LWCF Section 6(f) concurrence until the 

completion of the Tier 2 analysis.

National Park Service - Chattahoochee River National Recreation Area 

The Chattahoochee River National Recreation Area (CRNRA) is a heavily used recreational 

resource that attracts over 3 million visitors a year, approximately a third of whom engage in 

some form of water-based recreation, including boating, fishing, canoeing, kayaking, rowing, 

tubing and swimming. The National Park Service’s (NPS) principal concern related to 
Atlanta-Chattanooga High Speed Ground Transportation Project – ER 16-0572

2

recreational use of the river is public safety. Subsequent analysis should address the safety of 

water-based recreation within CRNRA, including an evaluation of the alternatives and the 

associated construction of any structures that have the potential to impact the river. 

The environmental effects of severe bank undercutting and erosion concerns the NPS because it 

leads to long-term habitat alterations that may negatively impact aquatic species. In particular, 

future analysis should evaluate the impact of construction and structures on organisms that 

benefit from a gravel or rocky substrate, including trout, shoal bass, mussels, and 

macroinvertebrates. In addition, an evaluation of the alternatives for construction/structures that 

have the potential to alter stream hydrology should consider the future impacts of bank erosion 

and the growing cost of measures taken to protect private and public property and facilities.

The NPS encourages the FRA and GDOT to use native grass seed or native vegetation for 

stabilizing road shoulders and streambanks at all stream crossings. Non-native species are easily 

transported downstream in the tributaries and can start new colonies of invasive species in the 

CRNRA. 

NPS encourages the FRA and GDOT to avoid using storm water control devices that contain 

plastic mesh or matting near the stream crossings. The mesh material is harmful to waterfowl and 

other bird species that inhabit the CRNRA and congregate and feed at the stream edges of the 

tributaries.

Visual and noise impacts to the park need to be topics addressed in the Tier 2 EIS. Natural and 

cultural sounds are integral components of the suite of resources and values that NPS managers 

are charged with preserving and restoring. NPS evaluates federal actions which may impact the 

human and natural environment within our parks with respect to our Organic Act mandates, 

including “...to conserve the scenery and the natural and historic objects and the wildlife therein 

and to provide for the enjoyment of the same in such a manner and by such means as will leave 

them unimpaired for the enjoyment of future generations.” The “scenery,” includes the natural 

soundscape, as well as the landscape (NPS 2006). NPS Director’s Order 47 delegates to the

parks the responsibility to preserve natural soundscapes and eliminate or mitigate inappropriate 

noise sources.

The acoustic environment of a national park, like air, water, or wildlife is a valuable resource 

that can easily be degraded or destroyed by inappropriate sound levels and frequencies. Intrusive 

sounds are of concern to the management of national parks because they can impede the ability 

to accomplish the NPS mission of resource protection. Visitors at many NPS units come with 

expectations of seeing, hearing, and experiencing phenomena associated with a specific natural 

or cultural environment, yet in many cases these environments are being increasingly impacted 

by artificial sounds.

Page 3-64, Upper Chattahoochee section - The Chattahoochee River does begin in northeast 

Georgia, but is does not begin near the Tennessee border. The headwaters are at Chattahoochee 

Gap, north of Helen, Georgia and within approximately 10 miles of the North Carolina border. 
Atlanta-Chattanooga High Speed Ground Transportation Project – ER 16-0572

3

Major tributaries in the vicinity of the project are Sope, Nancy, Rottenwood, Whitewater, and 

Long Island. 

Trail of Tears National Historic Trail

As noted, the Tier 1 Draft EIS identifies the Trail of Tears National Historic Trail (NHT) as 

being located within the alternatives currently under consideration. As the Federal 

administrators of this National Historic Trail, NPS requests that impacts to the Trail of Tears 

NHT, and its associated sites and viewshed, be considered during future planning and analysis

for this project. For continued consultation and coordination with NPS issues, please contact 

Steven Wright, NPS, Southeast Regional Office, Atlanta Federal Center, 1924 Building, 100 

Alabama Street, SW., Atlanta, Georgia, 30303, telephone (404) 507-5710. 

Coordination History with U.S. Fish and Wildlife Service (FWS) are as follows: 

August 22, 2007. A Notice of Intent was published in the Federal Register (Vol. 72, No. 162, 

Pages: 47121-47122). The Federal Highway Administration (FHWA) and Federal Railroad 

Administration (FRA) will be jointly preparing an Environmental Impact Statement with

Georgia Department of Transportation (GDOT) and Tennessee Department of Transportation 

(TDOT) on the impacts related to the proposed project.

August 23, 2007. We received a notice from the Assistant Director Fisheries and Habitat 

Conservation regarding a Notice of Intent for a 110-Mile High-Speed Ground Transportation 

Corridor from Atlanta to Chattanooga. The Department notified our Regional Office on 

September 10, 2007, that we would work with GDOT to assess the Department’s concerns 

related to the project.

March 28, 2008. We received a letter from GDOT dated March 14, 2008, requesting the 

Department to become a participating agency in coordination with the FRA, FHWA, and GDOT.

August 27, 2008. We received a letter from GDOT which acknowledged the Department’s 

participation in the planning process and included a list of contacts of other 

organizations/agencies involved in the project planning.

June 14, 2010. The Department received a letter from GDOT dated June 10, 2010, containing a 

Revised Coordination Plan Version (2.0): May 2010.

July 26, 2010. The Department sent a letter to GDOT, accepting the role as a participating 

agency in the project planning process.

August 5, 2010. The Department received a letter from GDOT dated August 2, 2010, containing 

a list of the participating agencies for the project’s National Environmental Policy Act (NEPA) 

planning process.
Atlanta-Chattanooga High Speed Ground Transportation Project – ER 16-0572

4

September 8, 2010. The Department received an early coordination letter from GDOT dated 

September 3, 2010.

September 13, 2010. We received a letter from GDOT dated September 10, 2010, requesting the

Department’s participating in a screening meeting to be held on September 23, 2010.

October 19, 2010. The Department participated in a meeting focused on introducing the project 

to participating agencies.

November 19, 2010. The Department submitted a letter to GDOT in response to their early 

coordination request, listing endangered and threatened species concerns related to the proposed 

project alignments. We requested that avoidance and minimization options be enacted for those 

listed species along the project corridor. The Department also requested several specific items 

related to reducing impacts to listed species: 1) GDOT consider clear-spanning any crossings of 

sensitive waters (in areas of designated critical habitat and where listed aquatics occur), 2) 

stormwater measures be enacted in the Etowah River system, and 3) the population of Tennessee 

Yellow-eyed Grass be avoided where it occurs near the US 411 / I-75 interchange

July 15, 2014. The Department received a letter from FHWA to FRA dated July 15, 2014, 

rescinding their role as a co-lead agency and changed to a participating agency.

October 13, 2016. The Georgia Ecological Field Office, Athens, GA, received notification from 

the Assistant Director of Ecological Services request for comments on the Draft Tier I 

Environmental Impact Statement.

The last coordination for the proposed project occurred with our office in September 2010. Since 

that coordination, there have been several new species listed and species previously listed have 

had their ranges expanded in Georgia. We would request an updated ArcGIS shapefile/layer or 

similar product of the 1,000-foot width of each of the three alignments discussed in the draft EIS.

The Department received a 2014 letter from Georgia Division of FHWA rescinding their role as 

a co-lead for this project. Is FHWA still a co-lead agency? If not, please update any reference to 

FHWA as a co-lead federal agency in the final EIS and any appendices where appropriate.

Protected Lands (Section 3.7). Each of these alignments has the potential to impact protected 

conservation lands that appear to have not been included in your analysis and could include 

conservation easements, conservation banks, and mitigation sites. Please be aware the sites 

should be avoided if possible and any impacts to these sites (as with other federal lands including 

Forest Service, Park Service) would have a higher mitigation ratio than typical impacts to 

unprotected lands to offset the impacts to these lands designated as protected for natural 

resources. In Section 3.7.5 [Potential Mitigation], please note that the cost of mitigating these 

impacts, if a monetary mitigation is chosen will be higher than typical ratios of unprotected 

lands.

Water Resources (Section 3.9). 
Atlanta-Chattanooga High Speed Ground Transportation Project – ER 16-0572

5

Please be aware that each of the three alignments cross through sensitive waters in some portions 

of the Upper Coosa (Etowah, Oostanaula, Coosawattee, and Conasauga). There are designated 

critical habitats for listed aquatics in portions of the rivers that will have either direct or indirect 

impacts by the project. Also, there are portions of each alignment that travel through watersheds 

identified as high priority during the 2015 revision of

Georgia’s State Wildlife Action Plan. These watersheds were identified as high priority based on 

the number of high priority aquatic species populations present in the watershed and the rarity of 

those species. There are also rivers in the region that are cold water and listed as trout streams. 

These sensitive water resources host listed or at-risk aquatic as well as a food-base for listed bats 

within the area. In areas where there will be increases of impervious surfaces (including rail 

lines, storage, maintenance, inspection facilities, stations, parking, new connecting roadways, 

and improvements to existing roadways), we request that the project developers consider efforts 

to ameliorate the effects of stormwater runoff and impacts to water temperature to any receiving 

waters.

Please consult our office under provisions of the Fish and Wildlife Coordination Act regarding 

any permanent or temporary impacts related to the project construction as well as postconstruction impacts to water resources. This would include construction activities using 

temporary work bridges, jetties, bank armoring or reinforcement, and erosion and sedimentation 

concerns. Because of karst geology and cave habitats along each of the alignments, please 

determine what geotechnical assessments are needed to ensure that the project would not pollute 

groundwater through natural fissures or during blasting/drilling activities.

Biological Resources (Section 3.10).

Comments specific to Table 3-25: I am unsure how this table is organized, but listing species by 

scientific name within each taxon group might be the easiest for those familiar with the species 

to assess the list for missing or inaccurate information. Does the State status listed in the Table 

refer to Georgia or Tennessee or both? Please clarify this information. Please cross-check the 

state listings for Georgia, several appear to be missing or inaccurate.

Northern Long-eared Bat is now listed as Threatened. Also, the range should be updated to 

include all counties within the project alignment (including Tennessee).

Rafineque's Big-eared Bat could occur along all three alignments. The range for this species is 

expected in the Blue Ridge, Ridge and Valley, and Southwestern Appalachians.

Red-cockaded Woodpecker does have a historical range in the northwestern part of Georgia; 

however, the species no longer occurs in this region and would not be of concern for any of the 

alignments.

In the table the scientific name for Freckled Darter is misspelled. Please correct to read Percina 

lenticula.
Atlanta-Chattanooga High Speed Ground Transportation Project – ER 16-0572

6

Both Monkeyface Orchid (Threatened) and Georgia Rockcress (Threatened) are now listed 

species. Please update the table to reflect that information. Please note that White Fringeless 

Orchid and Monkeyface Orchid are the same species (Platanthera integrilabia), with differing 

common names used by each state. Additionally, please note that Michaux’s Sumac and Dwarf

Sumac are the same species (Rhus michauxii). Please combine each of these into single rows.

Additional Comments related to Section 3.10:

Please be aware that there are over 100 species that are currently petitioned under the 

Endangered Species Act that occur or have occurred in Georgia. There are several species that 

have the potential to occur within the project corridor and could be listed before the project or 

project design will be completed. Our office will attempt to make recommendations, as early as 

possible, to minimize impacts and be protective of these species during our consultation with 

GDOT.

The Etowah HCP (http://etowahaquatichcp.org/), although not formally adopted by the 

Department as a Habitat Conservation Plan, gives guidance for the protection of water quality 

and listed aquatics within the Etowah River watershed. Please use these guides for stormwater 

protections within the Etowah and in areas draining to critical habitats for listed aquatics. 

Specifically assess Section 4 of the following report, which gives guidance for post-development 

stormwater management 

(http://www.etowahaquatichcp.org/research/documents/tech_rpt_stormwater_8_20_07.pdf).

In Section 3.10.5, the start of the second paragraph states potential mitigation strategies 

include... These efforts would be defined by the Department as minimization efforts (i.e. to 

minimize the impact to listed species and their habitats). For unavoidable impacts to listed 

species and their habitats, we would request that FRA consider requiring conservation banking 

and in-lieu fee mitigation. Conservation credits are currently available for impacts to Cherokee 

Darters at the Deerleap Conservation Preserve. Please consider in-lieu fee or in-kind mitigation 

for other aquatics and bats. There is a mechanism in place to accept in-lieu mitigation with The 

Conservation Fund for impacts to bat habitat and with The Nature Conservancy for impacts to 

aquatics.

Although the Draft EIS states that a large portion of each corridor alternative will occur within 

the existing right-of-way, there are occurrences of listed species within the existing right-of-way 

of I-75. We have records of critical habitat within and along both the Rome/I-75 and the East 

Corridors. These habitats should be avoided.

If your project will directly or indirectly affect hardwood forests, please conduct vegetation 

surveys to determine the level of consultation necessary with our agency, in addition to 

developing appropriate avoidance, minimization, and mitigation measures, if appropriate. If the 

project will directly or indirectly affect caves or other cave-like structures, please contact our 

office to assess impacts to these resources as maternity roost for Gray Bats or hibernacula for

Northern Long-eared Bats and other at-risk bat species. All listed bats and other at-risk bat 

species have been documented using man-made structures as roosts. Please complete inspections 

of all bridges, culverts, and structures that could be impacted by the project to determine if the 
Atlanta-Chattanooga High Speed Ground Transportation Project – ER 16-0572

7

structure is being utilized as a roost by bats. In addition, in sensitive areas, vibrations or blasting 

from construction activities could impact protected bats and nearby roosts. Please assess the 

trade-offs of using traditional and alternative construction methods and time of day restrictions 

for driving piles and other activities with high noise or vibrations.

As the proposed project design is developed, please consider assessing design measures to 

minimize impacts to terrestrial wildlife for the at-grade portions of the proposed alignments and 

birds and bats for all alignments, especially along commonly used flight paths and 

movement/migration corridors. It would be beneficial to conduct an analysis of potential 

mortality and fragmentation of habitat for species of concern.

Because a purpose of the proposed project is to enhance economic growth throughout the Project 

Area, please consider additional analyses for the Tier 2 NEPA or once the preferred alternative is 

selected (Section 3. 11). Please assess the project's impacts to listed species related to interrelated 

and interdependent actions. This should include any predictions or inclusions of the proposed 

project in state, county, municipal, or city planning documents for development along the

proposed project alignment. This assessment should catalog likely changes in habitat or 

impervious surface in those areas relative to the baseline conditions. If the project is expected to 

require the relocation of utility lines, other service lines, or existing facilities, please include the 

impacts (direct and indirect) on the listed species as a result of those impacts.

The Department has a continuing interest in working with the FRA, GDOT, and TDOT to ensure 

that project impacts to resources of concern are adequately addressed. If you have any questions 

or require further information, please contact Carrie Straight, at (706) 613-9493, ext. 227. I can 

be reached via email at joyce_stanley@ios.doi.gov or at (404) 331-4524.

Sincerely,

Joyce Stanley, MPA

Regional Environmental Officer

cc: Christine Willis - FWS

Michael Norris - USGS

Steven Wright - NPS

Robin Ferguson - OSRME

OEPC - WASH





Ms. Sarah Feinberg.

Administrator

Federal Railroad Administration

1200 New Jersey Avenue SE, MS-20

Washington, DC 20590

ATTN: Mr. John Winkle, Office of Railroad Policy and Development

RE: USFWS Log# 04EG1000-2017-TA-0134, GDOT P.I. No. T001684

Dear Mr. Winkle:

Please accept the following comments on the Tier 1 Draft Environmental Impact Statement for the proposed AtlantaChattanooga High Speed Ground Transportation Project (GDOT PI: T001684) dated September 2016, on behalf of 

Georgia Ecological Service, U.S. Fish and Wildlife Service. Please note for your files that Carrie Straight will be 

serving as Georgia Ecological Services’ contact for any future NEPA-related studies.

Coordination History with Georgia Ecological Services:

August 22, 2007. A Notice of Intent was published in the Federal Register (Vol. 72, No. 162, Pages: 47121-

47122). That the FHWA and FRA will be jointly preparing an Environmental Impact Statement with 

GDOT and TDOT on the impacts related to the proposed project.

August 23, 2007. The Service received a notice from the Assistant Director Fisheries and Habitat Conservation 

regarding a Notice of Intent for a 110-Mile High-Speed Ground Transportation Corridor from Atlanta 

to Chattanooga. The Service notified our Regional Office on September 10, 2007, that we would work 

with GDOT to assess the Service’s concerns related to the project.

March 28, 2008. The Service received a letter from GDOT dated March 14, 2008, requesting the Service to 

become a participating agency in coordination with the FRA, FHWA, and GDOT.

August 27, 2008. The Service received a letter from GDOT which acknowledged the Service’s participation in 

the planning process and included a list of contacts of other organizations/agencies involved in the 

project planning.

June 14, 2010. The Service received a letter from GDOT dated June 10, 2010, containing a Revised 

Coordination Plan Version (2.0): May 2010.

July 26, 2010. The Service sent a letter to GDOT, accepting the role as a participating agency in the project 

planning process.

August 5, 2010. The Service received a letter from GDOT dated August 2, 2010, containing a list of the 

participating agencies for the project’s National Environmental Policy Act (NEPA) planning process.

September 8, 2010. The Service received an early coordination letter from GDOT dated September 3, 2010.

September 13, 2010. The Service received a letter from GDOT dated September 10, 2010, requesting the 

Service’s participating in a screening meeting to be held on September 23, 2010.

October 19, 2010. The Service participated in a meeting focused on introducing the project to participating 

agencies.

United States Department of the Interior

Fish and Wildlife Service

105 Westpark Drive, Suite D

Athens, Georgia 30606

West Georgia Sub Office October 31, 2016

P.O. Box 52560

Ft. Benning, Georgia 31995-2560

Coastal Sub Office

4980 Wildlife Drive

Townsend, Georgia 31331
October 31, 2016

Letter to Ms. Sarah Feinberg.

Federal Railroad Administration

RE: GDOT Project T001684

November 19, 2010. The Service submitted a letter to GDOT in response to their early coordination request, 

listing endangered and threatened species concerns related to the proposed project alignments. The 

Service requested that avoidance and minimization options be enacted for those listed species along the 

project corridor. The Service also requested several specific items related to reducing impacts to listed 

species: 1) GDOT consider clear-spanning any crossings of sensitive waters (in areas of designated 

critical habitat and where listed aquatics occur), 2) stormwater measures be enacted in the Etowah 

River system, and 3)the population of Tennessee Yellow-eyed Grass be avoided where it occurs near 

the US 411 / I-75 interchange

July 15, 2014. The Service received a letter from FHWA to FRA dated July 15, 2014, rescinding their role as a 

co-lead agency and changed to a participating agency.

October 13, 2016. The Georgia Ecological Field Office, Athens, GA, received notification from the Assistant 

Director of Ecological Services request for comments on the Draft Tier I Environmental Impact 

Statement.

The last coordination for the proposed project occurred with our office in September 2010. Since that coordination, there 

have been several new species listed and species previously listed have had their ranges expanded in Georgia. We would 

request an updated ArcGIS shapefile/layer or similar product of the 1,000-foot width of each of the three alignments 

discussed in the draft EIS.

The Service received a 2014 letter from Georgia Division of FHWA rescinding their role as a co-lead for this project. Is 

FHWA still a co-lead agency? If not, please update any reference to FHWA as a co-lead federal agency in the final EIS 

and any appendices where appropriate. 

Protected Lands (Section 3.7). Each of these alignments has the potential to impact protected conservation lands that 

appear to have not been included in your analysis and could include conservation easements, conservation banks, and 

mitigation sites. Please be aware the sites should be avoided if possible and any impacts to these sites (as with other 

federal lands including Forest Service, Park Service) would have a higher mitigation ratio than typical impacts to nonprotected lands to offset the impacts to these lands designated as protected for natural resources. In Section 3.7.5 

[Potential Mitigation], please note that the cost of mitigating these impacts, if a monetary mitigation is chosen will be 

higher than typical ratios of unprotected lands.

Water Resources (Section 3.9). Please be aware that each of the three alignments cross through sensitive waters in 

some portions of the Upper Coosa (Etowah, Oostanaula, Coosawattee, and Conasauga). There are designated critical 

habitats for listed aquatics in portions of the rivers that will have either direct or indirect impacts by the project. Also, 

there are portions of each alignment that travel through watersheds identified as high priority during the 2015 revision of 

Georgia’s State Wildlife Action Plan. These watersheds were identified as high priority based on the number of high 

priority aquatic species populations present in the watershed and the rarity of those species. There are also rivers in the 

region that are cold water and listed as trout streams. These sensitive water resources host listed or at-risk aquatic as 

well as a food-base for listed bats within the area. In areas where there will be increases of impervious surfaces 

(including rail lines, storage, maintenance, inspection facilities, stations, parking, new connecting roadways, and 

improvements to existing roadways), we request that the project developers consider efforts to ameliorate the effects of 

stormwater runoff and impacts to water temperature to any receiving waters. 

Please consult our office under provisions of the Fish and Wildlife Coordination Act regarding any permanent or 

temporary impacts related to the project construction as well as post-construction impacts to water resources. This 

would include construction activities using temporary work bridges, jetties, bank armoring or reinforcement, and erosion 

and sedimentation concerns. Because of karst geology and cave habitats along each of the alignments, please determine 

what geotechnical assessments are needed to ensure that the project would not pollute groundwater through natural 

fissures or during blasting/drilling activities. 
October 31, 2016

Letter to Ms. Sarah Feinberg.

Federal Railroad Administration

RE: GDOT Project T001684

Biological Resources (Section 3.10). 

Comments specific to Table 3-25: I am unsure how this table is organized, but listing species by scientific name within 

each taxon group might be the easiest for those familiar with the species to assess the list for missing or inaccurate 

information. Does the State status listed in the Table refer to Georgia or Tennessee or both? Please clarify this 

information. Please cross-check the state listings for Georgia, several appear to be missing or inaccurate.

Northern Long-eared Bat is now listed as Threatened. Also, the range should be updated to include all counties within 

the project alignment (including Tennessee). 

Rafineque's Big-eared Bat could occur along all three alignments. The range for this species is expected in the Blue 

Ridge, Ridge and Valley, and Southwestern Appalachians.

Red-cockaded Woodpecker does have a historical range in the northwestern part of Georgia; however, the species no 

longer occurs in this region and would not be of concern for any of the alignments.

In the table the scientific name for Freckled Darter is misspelled. Please correct to read Percina lenticula.

Both Monkeyface Orchid (Threatened) and Georgia Rockcress (Threatened) are now listed species. Please update the 

table to reflect that information. Please note that White Fringeless Orchid and Monkeyface Orchid are the same species 

(Platanthera integrilabia), with differing common names used by each state. Additionally please note that Michaux’s 

Sumac and Dwarf Sumac are the same species (Rhus michauxii). Please combine each of these into single rows.

Additional Comments related to Section 3.10:

Please be aware that there are over 100 species that are currently petitioned under the Endangered Species Act that occur 

or have occurred in Georgia. There are several species that have the potential to occur within the project corridor and 

could be listed before the project or project design will be completed. Our office will attempt to make recommendations, 

as early as possible, to minimize impacts and be protective of these species during our consultation with GDOT.

The Etowah HCP (http://etowahaquatichcp.org/), although not formally adopted by the Service as a Habitat Conservation 

Plan, gives guidance for the protection of water quality and listed aquatics within the Etowah River watershed. Please 

use these guides for stormwater protections within the Etowah and in areas draining to critical habitats for listed aquatics. 

Specifically assess Section 4 of the following report, which gives guidance for post-development stormwater 

management (http://www.etowahaquatichcp.org/research/documents/tech_rpt_stormwater_8_20_07.pdf).

In Section 3.10.5, the start of the second paragraph states potential mitigation strategies include... These efforts would be

defined by the Service as minimization efforts (i.e. to minimize the impact to listed species and their habitats). For 

unavoidable impacts to listed species and their habitats, we would request that FRA consider requiring conservation 

banking and in-lieu fee mitigation. Conservation credits are currently available for impacts to Cherokee Darters at the 

Deerleap Conservation Preserve. Please consider in-lieu fee or in-kind mitigation for other aquatics and bats. There is a 

mechanism in place to accept in-lieu mitigation with The Conservation Fund for impacts to bat habitat and with The 

Nature Conservancy for impacts to aquatics.

Although the Draft EIS states that a large portion of each corridor alternative will occur within the existing right-of-way, 

there are occurrences of listed species within the existing right-of-way of I-75. We have records of critical habitat within 

and along both the Rome/I-75 and the East Corridors. These habitats should be avoided.

If your project will directly or indirectly affect hardwood forests, please conduct vegetation surveys to determine the 

level of consultation necessary with our agency, in addition to developing appropriate avoidance, minimization, and 

mitigation measures, if appropriate. If the project will directly or indirectly affect caves or other cave-like structures, 

please contact our office to assess impacts to these resources as maternity roost for Gray Bats or hibernacula for 

Northern Long-eared Bats and other at-risk bat species. All of the listed bats and other at-risk bat species have been 

documented using man-made structures as roosts. Please complete inspections of all bridges, culverts, and structures 

that could be impacted by the project to determine if the structure is being utilized as a roost by bats. In addition, in 

sensitive areas, vibrations or blasting from construction activities could impact protected bats and nearby roosts. Please 

assess the trade-offs of using traditional and alternative construction methods and time of day restrictions for driving 

piles and other activities with high noise or vibrations. 
October 31, 2016 

Letter to Ms. Sarah Feinberg. 

Federal Railroad Administration 

RE: GDOT Project TOO 1684 

As the proposed project design is developed, please consider assessing design measures to minimize impacts to 

terrestrial wildlife for the at-grade portions of the proposed alignments and birds and bats for all alignments, especially 

along commonly used flight paths and movement/migration corridors. It would be beneficial to conduct an analysis of 

potential mortality and fragmentation of habitat for species of concern. 

Because a purpose of the proposed project is to enhance economic growth throughout the Project Area, please consider 

additional analyses for the Tier 2 NEPA or once the preferred alternative is selected (Section 3. 11 ). Please assess the 

project's impacts to listed species related to interrelated and interdependent actions. This should include any predictions 

or inclusions of the proposed project in state, county, municipal, or city planning documents for development along the 

proposed project alignment. This assessment should catalog likely changes in habitat or impervious surface in those 

areas relative to the baseline conditions. If the project is expected to require the relocation of utility lines, other service 

lines, or existing facilities, please include the impacts ( direct and indirect) on the listed species as a result of those 

impacts. 

If you have any questions or require further information, please contact staff biologist Carrie Straight, at 706-61 3-9493, 

ext. 227. 

cc: Stephanie Nash, USFWS 

file 

Sincerely, 

~(::w!:~ 

Field Supervisor